Document 49ezkVwRabJBd06Kwg758vGe

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III Four Penn Center 1600 John F Kennedy Blvd Philadelphia, Pennsylvania 19103-2852 Mr. Erik Roberts Environmental Compliance Manager Charleston Sanitary Board 208 26th St, W Charleston, West Virginia 25387 Re: Sanitary Board of the City of Charleston, West Virginia Pretreatment Compliance Audit Dear Mr. Roberts: Thank you for your cooperation and participation during the Pretreatment Compliance Audit conducted on January 25 and 26, 2023. The compliance audit of the City of Charleston Sanitary Board's (CSB) publicly owned treatment works (POTW) approved pretreatment program was done as part of the Environmental Protection Agency's (EPA) audit of the West Virginia Department of Environmental Protection's (WVDEP) authorized Clean Water Act (CWA) National Pollutant Discharge Elimination System's (NPDES) Pretreatment Program. The audit of Charleston Sanitary Board's pretreatment program revealed a generally well implemented program, but there are areas of the program that need to be addressed. Please find enclosed a copy of the POTW Pretreatment Program Audit Report and relevant attachments. While the required and recommended changes to CSB's pretreatment program can be found at Section X of the report, a summary of the findings is as follows and follows the report organization and Attachment 5, Audit Action Items Checklist. The below summary may not include all findings identified in the audit report and audit action items checklist. A. Legal Authority - The review of CSB's sewer use ordinance (SUO) revealed several differences when compared to the General Pretreatment Regulations. CSB must revise its SUO to align inconsistent or absent definitions, prohibited discharges, permit conditions, reporting requirements, upset and bypass provisions, and remedies for noncompliance. These required corrective actions are located at Section X, Subsection A of the report and Attachment 1, which provides the full POTW Legal Authority Review Checklist. Despite the need to revise and update language, the structure of the existing SUO closely resembles the Model SUO published by EPA. B. Application of Standards - The review of CSB's application of the National Pretreatment Standards suggests that CSB (1) include in its SUO and industrial discharge permits the prohibition of toxic gases, vapors, or fumes, and hazardous waste pharmaceuticals, and (2) pursue the modification of its existing slate of applied local limits to ensure proper procedural approval from WVDEP, CSB's Approval Authority. Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free. Customer Service Hotline: 1-800-438-2474 Significantly, it does not appear that CSB has requested formal approval from WVDEP for several pollutants that are limited within its SUO, nor is there clear justification or reference to the SUO for several limited parameters within CSB's issued permits. And, while approval from WVDEP is not necessary for the distribution of maximum allowable industrial loadings, it is strongly recommended that CSB modify any industrial user discharge permits where local limits are not minimally allocated. Further, to align CSB's program with the objectives of the General Pretreatment Regulations, CSB must conduct an evaluation of the need for numerical local limits for conventional pollutants that have caused pass-through and/or interference at the POTW. C. Control Mechanisms - The review of CSB's industrial user discharge permit issued to the significant industrial user, United Dairy, Inc., indicates that it is inconsistent with the General Pretreatment Regulations. CSB must revise its industrial user discharge permit template consistent with the regulations. The required corrective actions are located at Section X, Subsection C of the report and Attachment 3, which provides the full Permit Form Review. D. Compliance Monitoring - CSB demonstrates a robust inspection and sampling regime of its permitted industrial users; however, CSB must ensure that sampling is done independently with regards to access to the sampling point(s), and that sampling is done at all points where an industrial user is connected to the collection system where possible and appropriate. In addition to minor recommended revisions to CSB's sampling and inspection forms and required bolstering of recordkeeping, EPA recommends CSB randomly sample permitted SIUs, specifically United Dairy, Inc. Independent, complete, and random sampling is vital to identify any occasional and continuing noncompliance of SIUs. E. Enforcement - When necessary, CSB properly enforces against violations of industrial discharge permit limitations and conditions. This was evidenced by resolved pass-through and interference issues, and a relatively minor violation of an industrial discharge limit in April 2021. Though, upon inspection of CSB's files, there does not appear to be a complete Enforcement Response Plan (ERP). CSB must create an ERP to ensure consistency across all enforcement actions addressing noncompliance. F. Data Management - As discussed during the audit, CSB has continued to transition its written records and procedures to an electronic format. Within these electronic records, the Audit Team was unable to locate a collection of submitted one-time compliance reports by dental dischargers. CSB will need to clarify if it is compliant with the Dental Effluent Guidelines as it relates to these reports. Further, in evaluation of how CSB receives records from permitted facilities, it is important to refer to the requirements of the Cross-Media Electronic Reporting Rule (CROMERR) and ensure that CSB accept the submittal of reports in paper format until CSB would seek approval under CROMERR. Additionally, as a point of clarification on its procedures, CSB must revise its evaluation process of significant industrial users and categorical industrial users to ensure consistency with the definitions at 40 C.F.R. Part 403. G. Resources - No issues were found relating to the resources devoted to the current implementation of CSB's pretreatment program. Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free. Customer Service Hotline: 1-800-438-2474 EPA requests that CSB review the corrective actions summarized above and enclosed in the full audit report, and provide a proposed action plan within 60 days of receipt of this report. For those items not immediately addressed, please include a planned completion date. If you have any questions or comments regarding this matter, please contact Aron Possler of my staff at possler.aron@epa.gov or (215) 814-2780. Sincerely, JESSICA MARTINSEN Digitally signed by JESSICA MARTINSEN Date: 2023.06.13 16:19:50 -04'00' Jessica Martinsen, Chief Permits Section Clean Water Branch Enclosure cc: Matthew Sweeney, WVDEP Netar Wadhwa, WVDEP Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free. Customer Service Hotline: 1-800-438-2474 Audit Date(s) January 25-26, 2023 CSB POTW PRETREATMENT PROGRAM AUDIT POTW Name Sanitary Board of the City of Charleston, West Virginia Contact Name Erik A. Roberts Address E-Mail Address Title Environmental Compliance Manager 208 26th Street, Charleston, WV 25312 eroberts@csb-wv.com Should this be the person on the mailing list? Telephone (304) 552-2414 Yes No X Name 1 Aron Possler 2 Natalie Sanchez- Gonzalez 3 Margaret Green 4 Ryan Shuart 5 James Kline Title Life Scientist Life Scientist Participants Organization EPA Region 3 EPA Region 3 Environmental Engineer Life Scientist Physical Scientist EPA Headquarters EPA Region 3 EPA Region 3 Telephone (215) 814-2780 (215) 814-2078 (202) 564-7011 (215) 814-2714 (304) 234-0263 NOTE: For Sections I through VIII, complete background sections based on information in pretreatment files and all other sections based on discussion with POTW personnel. SECTION I: GENERAL INFORMATION A. Background - Complete prior to onsite activity 1 Date of last annual report: 2/16/2022 List unresolved issues. N/A 2 Date of last audit: 7/3/2019 List unresolved issues. Hg, Zn, and flow limits missing from the permits for United Dairy and CAMC Non-domestic wastewater source description missing from the permits for United Dairy (no high BOD milk reject water) and CAMC Description of pretreatment to non-domestic wastewater prior to POTW and BMPs specific to hospitals missing from the permit for CAMC 3 Date of last Inspection: 1/31/2021 (in the form of a "virtual" inspection) List unresolved issues. N/A 4 List any other outstanding issues. N/A 5 Number of treatment plants (verify during onsite activity): 1 NPDES Number Issuance Date Expiration Date WV0023205 6 a. Compliance with NPDES limits March 09, 2022 March 08, 2027 Year NPDES Limits Exceedances 2016 Fecal Coliform, TSS, BOD 2017 Fecal Coliform, TSS, BOD 2018 TSS, SS % Removal, Fecal Coliform 2019 Fecal Coliform 2020 Fecal Coliform, TSS, BOD 2 of 40 b. Compliance with sludge limits (report only, sludge disposed to the SIU Charleston Landfill) Year Sludge Issues 2016 None 2017 None 2018 None 2019 None 2020 None 7 Any effluent or sludge violations in the past 12 months? Yes No X Parameter violated Date(s) Reported Cause(s) pH, TSS Disinfection 12/2021, 6/2022 Fecal Coliform 6/30/22, 8/31/22 BOD, SS % Removal 8/31/2022 TSS Disinfection, TSS Removal 8/31/2022 8 Does the permit(s) require pretreatment implementation? Yes No Discrepancies X between West Virginia general NPDES pretreatment implementation language and CSB NPDES permit language 9 Does the permit(s) have a schedule for pretreatment Yes No N/A (2014 SUO) program implementation/modification? X Activity Milestone Date Completion Date Submit list of pollutants and sampling plan N/A N/A Submit local limits reevaluation Y Permit reissuance Submit response to comments on reevaluation N/A N/A Adopt local limits N/A N/A 3 of 40 10 List any pending program modifications and current status (verify during onsite activity). LTCP, compliance schedule for implementation of plan (p. 57 of NPDES permit) SECTION II: LEGAL AUTHORITY A. Background - Complete prior to onsite activity 1 List all municipalities served by the POTW and applicable legal authorities (verify during onsite activity). Municipality Name Ordinance Date Agreement Date Any IUs? (X all that apply) SIUs IUs None City of Charleston, West Virginia 9/16/2013 N/A 5 2 Was a complete legal authority review previously conducted? Yes No X Describe any inadequacies not yet corrected. See above 3 Has the POTW submitted legal authority revisions based on the streamlining amendments? If no, attach ordinance review. If yes, list status. N/A Date 2019 Reviewer Netar Wadhwa Yes No X 4 of 40 4 Does the POTW's ordinance provide for variances and/or special agreements? If yes, does it: Yes specifically prohibit changes to both categorical standards and other federal pretreatment requirements (e.g., reporting)? establish a cap based on the current MAIL for revised local limits? require that the revised limit or requirement be granted in writing? B. Current 1 Update POTW's progress on correcting N/A deficiencies, including streamlining. 2 Does the POTW intend to adopt any additional N/A optional streamlining provisions? 3 When did the POTW last review its ordinance to ensure that it is consistent with the POTW's current program implementation? 4 Do any outside agencies implement all or part of the pretreatment program within the POTW's service area? 2019 Yes If yes, list agency and part of program N/A implemented. If yes, how does the POTW ensure the adequacy N/A of implementation in these areas? Yes No X No N/A X X X No X SECTION III: APPLICATION OF STANDARDS A. Background - Complete prior to onsite activity 1 Has the POTW stated in any annual reports in the last five years that problems Yes No (e.g., inhibition/upset, pass through, sludge contamination, corrosion, toxic X fumes, etc.) have been caused by IU discharges? If yes, describe the incident and actions taken. See notes from the 2021 and 2022 annual reports. Excursion events during October 2020. 5 of 40 United Dairy (2021, 2022) violati ons caused issues of P/I 2 a. Date of last local limits submission: 2022 b. Date of acceptance: See below c. Date of approval: NPDES permit issuance date d. If not accepted and approved, list status: Limits not needed; only mass limits for Hg and Zn 3 Are the approved local limits allocated in the submission or left to be allocated in the permits? Yes; internal spreadsheet used to allocate limits 4 Does the POTW have any BMPs approved as part of its local limits? Yes No X If yes, describe. FOG program and United Dairy BMP 5 Did the POTW include loadings from waste haulers in its local limit development? Yes No N/A X 6 Has the POTW received approval for removal credits? Yes No X If yes, for what pollutants. N/A 7 Has the POTW revised or proposed to revise its approved program to establish Yes No the classification of nonsignificant categorical industrial users? X If yes, list current status of approval. N/A 8 Has the POTW revised or proposed to revise its approved program to establish Yes No the classification of middle tier categorical industrial users? X If yes, list current status of approval. N/A 9 Has the POTW revised or proposed to revise its approved program to provide Yes No for equivalent mass limits in place of concentration based categorical X standards? If yes, list current status of approval. N/A 10 Has the POTW revised or proposed to revise its approved program to provide Yes No for equivalent concentration limits in place of mass based categorical X standards? If yes, list current status of approval. N/A 11 List all CIUs subject to productionbased standards (with category): No CIUs 6 of 40 12 List all CIUs for which concentration- Limits evaluation demonstrated no concentration-based limits were based limits were applied in place of needed as the influent load is currently less than 50% of the new mass-based standards: MAHL for all pollutants included in the evaluation. 13 List all CIUs for which mass-based N/A limits were applied in place of concentration-based standards: 14 List all CIUs for which a pollutants N/A not present waiver has been granted: 15 Does the approved program include procedures for acceptance of hauled waste? Yes No X If yes, describe. N/A B. Industrial User Characterization 1 When was the last full IWS completed? 2 How does the POTW locate new IUs? 2022 Survey contents o IUs on the list include non-domestic IUs that have the potential to negatively impact CSB's treatment system due to the size of the discharge and the nature of the pollutants (whether or not they be a CIU) SIUs are identified as follows: o IUs that cause pass-through or interference of pollutants with the wastewater's treatment process, cause sludge contamination, or pose a safety threat to workers at CSB o IUs producing >25,000 gal/day 3 How does the POTW investigate changes at existing IUs (e.g., non-SIU to SIU, NSIU to CIU)? 4 How are changes discovered in contributing jurisdictions? 5 Does the POTW maintain a list of non-SIUs? SIU annual inspections, grease trap inspections for those NSIUs covered under the FOG program, grit separator inspections for car washes N/A - No contributing jurisdictions Yes No Update freq. X C. Local Limits 1 Is the POTW aware of instances of pass through, treatment plant Yes No 7 of 40 inhibition/upset, sludge contamination, or other problems (excessive corrosion, X toxic fumes, sewer blockages, etc.) during the past year, including problems caused by conventional wastes? If yes, describe incident and actions taken. CSB received a plan from United Dairy to correct actions that caused pass-through at the POTW. CSB issued NOVs and published SNC in the newspaper (1/2023) in addition to those publications 2020-2021. Fines were assessed and collected April 1, 2022, totaling an amount of $33,000. 2 Is the POTW aware of any instances where workers have experienced industrial Yes No waste-related injuries or illnesses? X If yes, describe. N/A 3 If the POTW allocates local limits through the permits, do they have a mechanism to track the allocations? If yes, describe. N/A 4 Has the POTW encountered any problems implementing applicable BMPs? If yes, describe. N/A 5 What has the POTW done to address exceedances of the N/A influent, effluent, and sludge goals (most recent year)? D. Standards and Requirements for IUs 1 Does the POTW report any questions/problems in the categorization of IUs? If yes, describe. N/A 2 List all IUs where the combined wastestream formula was applied. N/A - no CIUs 3 Does the POTW have a list of new source dates for all categorical industries? 4 Has the POTW made a specific evaluation of process construction dates in relation to the new source date of any applicable categorical standards? 5 List all IUs currently regulated under Pretreatment Standards for New Sources. Yes No N/A X Yes No N/A X Yes No N/A X Yes No N/A X Yes No N/A X 8 of 40 6 If present1, does the POTW regulate CIUs N/A - no CIUs for which a no discharge standard exists? 7 Has the POTW applied equivalent concentration limits to any users subject to Yes mass-based standards in place of mass limits, other than those listed in Section A.12? If yes, describe. N/A 8 Has the POTW applied equivalent mass limits to any users subject to Yes concentration-based standards in place of concentration limits, other than those listed in Section A.13? If yes, describe. N/A 9 Has the POTW granted any net/gross variances? Yes If yes, describe. N/A E. Hauled Wastes 1 Does the POTW accept wastes by truck, rail, or dedicated pipe (If no, go to Yes Section V) What types of waste are accepted? 2 Are any hauled wastes hazardous? Yes If no, how does the POTW confirm this? 3 Has the POTW designated a specific discharge point(s) for the waste Yes (403.5(b)(8))? If yes, where? 4 Does the POTW have a control mechanism for regulating the waste Yes (403.8(f)(1)(iii))? If yes, describe the mechanism and to whom it is issued. No N/A X No N/A X No N/A X No N/A X No N/A X No N/A X No N/A X 1 CIUs with standards requiring no discharge include: feedlots, inorganic chemicals manufacturing, fertilizer manufacturing, iron & steel manufacturing, nonferrous metals manufacturing, steam electric power generating, timber products, oil & gas extraction, paint formulating, ink formulating, pesticide chemicals, battery manufacturing, metal molding & casting, porcelain enameling, aluminum forming, and nonferrous metals forming & metal powders. 9 of 40 5 Does the control mechanism include all applicable categorical and local standards (403.8(f)(2)(iii))? 6 Does the POTW sample/require sampling of hauled waste? If yes, describe the sampling program. Yes No N/A X Yes No N/A X SECTION IV: CONTROL MECHANISM A. Background - Complete prior to onsite activity 1 Provide the # of IUs based on the most recent file information: SNIUs 5 CIUs MTCIUs 2 a. List all SIUs without control mechanisms or with N/A expired control mechanisms (and the date of expiration). b. Identify which of these users have administratively N/A extended control mechanisms. 3 According to the approved program, what type of control mechanism was intended to be used to regulate industrial discharges? 4 What industries does the approved program indicate will be regulated through this control mechanism? 5 What is the maximum control mechanism duration indicated in the approved program? 6 Has the POTW revised or proposed to revise its approved program to allow for general control mechanisms? If yes, list current status of approval. N/A 7 Does the annual report indicate that any users are covered by a general control mechanism? If yes, list the users that are covered by each general control mechanism. B. Control Mechanism 1 Give the current # of IUs: N/A SNIUs CIUs 5 10 of 40 MTCIUs NSCIUs Other 2 Total 7 Permits Hospitals, landfill, dairy processing facility Three years (p. 27 of SUO) Yes No X Yes No X NSCIUs Other 2 Total 7 2 Have all expired SIU control mechanisms been re-issued? Yes X If no, explain. N/A 3 What type of control mechanism is currently being used? Permits 4 Has the POTW issued any general control mechanisms other than those Yes listed in Section A.7? If yes, list the users that are covered by each additional N/A general control mechanism. No N/A No No X intention on adopting the optional streamlin ing provision for general control mechanis ms SECTION V: COMPLIANCE MONITORING A. Background - Complete prior to onsite activity 1 As required by the approved program, list the frequency for: SNIU CIU MTCIU NSCIU POTW sampling of IUs 1x/yr N/A N/A N/A POTW inspection of IUs 1x/yr N/A N/A N/A IU self-monitoring 2x/yr2 N/A N/A N/A IU reporting N/A N/A N/A 2 This frequency of self-monitoring applies to any industry which is permitted, including SIUs and NSIUs; requirement is written into the IU discharge permit. 11 of 40 2 In the last year, indicate frequency of: SNIU CIU MTCIU NSCIU POTW sampling of IUs 1x/yr N/A N/A N/A POTW inspection of IUs 1x/yr N/A N/A N/A IU self-monitoring 2x/yr N/A N/A N/A IU reporting N/A N/A N/A If less than required by the approved program or less than N/A 1/yr (403.8(f)(2)(v)), explain. 3 List all SIUs that were found to have been not sampled or not inspected in the last annual report. Name of IU NS/NI/B3 Reason CAMC Womens and Childrens CAMC Memorial NI COVID-19, offsite inspections in form of survey 4 Has the POTW revised or proposed to revise its Yes No approved program to provide for waivers for pollutants X not present? If yes, list current status of approval. N/A 5 Has the POTW granted any monitoring waivers for Yes No pollutants not present? X If yes, list the user and the pollutants for N/A which the waiver was granted. 3 NS = not sampled, NI = not inspected, B = both not sampled and not inspected. 12 of 40 B. POTW Sampling and Inspection 1 Update status of users listed in the table in A.3: Name of IU All CAMC hospitals 2 Does the POTW conduct all of the sampling for any of its users? NS/NI/B NI (corrected) Yes If yes, does the POTW re-sample within 30 days of Yes discovering a violation? X 3 Does the POTW monitor for all categorical pollutants at Yes least once per year? If no, why not? N/A Does the POTW monitor for all local limit pollutants at Yes least once per year? X If no, how does the POTW determine which pollutants N/A to sample? 4 For users with a monitoring waiver for pollutants not N/A present, how often does the POTW monitor for the waived pollutants? 5 Does the POTW have written standard operating Yes procedures for sampling industrial users? X Date planned/completed Sampled 2022 in-person No Compliance sampling x may be done by CSB or by the IU (p. 36 of SUO); 2021 AR states that questionnaires were sent in lieu of conducting sampling at CAMC sites due to COVID-19 No Page 37 of SUO states that resampling should be done by the IU within 30 days of violation No N/A X No No 13 of 40 6 Does the POTW collect its own samples, or are they collected by a contractor? CSB samples for compliance at all the SIUs 7 Are pH, oil & grease, cyanide, volatile organics, total Yes phenol, sulfide, and hexavalent chromium collected by grab sample? X* No N/A *Not required for hexavalent chromium 8 When collecting grab samples, how many grab samples Minimum of four (where no historical data exists), are used? lower minimum permitted where historic data exists (pg. 35 of SUO); later on pg. 35, states need number of grab samples to assure compliance with applicable pretreatment standard requirement Has the POTW documented the reasons for the No number of grab samples used for each IU? 9 Are composite samples used for all other pollutants to Yes No N/A evaluate compliance with: Categorical standards? X Local limits? X Is any unannounced sampling conducted? X 10 Is POTW prepared to take samples on short notice (i.e., X vehicles, personnel, preservatives, etc. available)? 11 How much time normally elapses between sample collection and obtaining analytical results? Depends on parameters - analyzed within the holding time per parameter. Sample results after analysis average: 20 days. If something has sensitive turn-around time, will highlight on lab sheet. Follows part 136 methods. 12 Has the POTW evaluated all of its users for the need Yes for a slug control plan? X No IU permit applications ask about spill prevention measures and slug control plans in section VI. Assume questions at section VI of application counts as evaluation for need of plan. 13 Has the POTW documented and maintained the Yes No N/A documentation of the slug control evaluations? X 14 of 40 14 What factors does the POTW consider in determining whether a user is required to develop a slug/spill control plan? 15 Do the POTW's annual inspections include an evaluation of facility changes that might impact the need for a slug control plan? Section VI of permit application: presence of drains in chemical storage and manufacturing areas, whether storage areas are diked or self-contained (and volume of tanks or dikes), where spills would discharge into. Yes No X 16 Does the POTW have procedures (e.g., identify waste, Yes No response personnel, identify key manholes, etc.) and equipment to investigate causes and sources of unknown slugs/spills to the POTW (including collection X system)? If yes, describe. N/A C. IU Self-Monitoring and Reporting 1 When are user self-monitoring reports due (e.g., 30 days after the monitoring period)? Depends on the user, different frequencies of sample receipts. Self-monitoring reports are received primarily in electronic format. 2 How does the POTW verify that IUs report all No current procedures. sample results if they sample more frequently than required? 3 Do any IUs discharge hazardous waste? Yes No Hospital wastes from all CAMC hospitals X are prohibited per their permits If no, how does POTW verify this? Such discharge is prohibited per permit language. No drains in the rooms containing hazardous wastes. Permit language includes general list of hazardous wastes not permitted in discharge. If yes, has the IU submitted the proper notifications Yes No N/A (403.12(p))? X 4 Does the POTW have procedures to monitor and control IUs when they close? Yes No X If yes, describe. Block and cap off the discharge once industry closes 15 of 40 SECTION VI: ENFORCEMENT A. Background - Complete prior to onsite activity 1 Has the POTW revised its approved ERP based on the Yes No N/A new SNC definition? X If yes, does it include all of the changes or only the required changes? Not all changes at 403.8(f)(2)(viii) were included in the SNC definition at Sec. 118-212 of CSB SUO 2 Based on the most recent file data, list the SIUs in SNC (indicate period). Name of IU 1st quarter of SNC SNC parameters Describe enforcement taken with date United Dairy, Inc. February/ March 2022 Inhibition, failure to pretreat, failure to report DMR NOVs and Fines Scheduled compliance date Currently in compliance B. Enforcement 1 When the POTW receives IU self-monitoring reports, how does it evaluate user compliance, including limits, completeness and timeliness of reports, and submission of resampling data? When does this evaluation occur? 2 How often does the POTW evaluate for SNC? 3 Does the POTW document its SNC evaluation? For what period was the last evaluation completed? 4 Is the POTW using the new SNC definition? If yes, describe which parts of the new definition are used. 5 Have there been instances where the POTW found the responses in its ERP to be inappropriate? If yes, explain. N/A Report timeliness, DMR signature and values Day of DMR receipt Monthly focus on United Dairy. Not evaluating for SNC for other SIUs. Yes, internal spreadsheet and publication December 2022, United Dairy Yes, but not an exact match to 40 CFR 403.8(f)(2)(vii) Yes No N/A X 16 of 40 6 Has POTW taken enforcement against all instances of Yes No pass through/interference in the last year? If no, why? If yes, describe. 7 Update based on most recent SNC period (identify period). Name of IU 1st quarter of SNC SNC parameters Describe enforcement taken with date N/A X Scheduled compliance date SECTION VII: DATA MANAGEMENT AND PUBLIC PARTICIPATION A. Data Management 1 Are all records maintained for at least 3 years? Yes No X 2 How does the POTW keep up-to-date on regulations and technical guidance for the pretreatment program? During audits for CSB or upon permit reissuance. WVDEP forwards updates and trainings to CSB occasionally, EPA offered training where interests lie. B. Public Participation 1 Are records available to the public (403.14(c))? 2 Have IUs requested that data be kept confidential? If yes, what type of data was it, and how has the POTW N/A handled it? Yes No X Yes No X SECTION VIII: PROGRAM RESOURCES 1 Approximately how many person-years does the POTW devote to the pretreatment program? 0.8 FTEs 2 In what areas does the POTW need additional resources? Generally short-staffed 17 of 40 3 What additional activities (if any) has the POTW undertaken to further the goals of the pretreatment program? 4 What has the POTW done to incorporate P2 (Pollution Prevention) practices into its pretreatment program? Fats, Oils, and Grease (FOG) Program - effective in reducing maintenance costs, preventative maintenance, public service announcements and media-wide education about "flushable" wipes. Dental amalgam program implemented. FOG Program, wipes announcements, inspection of car wash grit separators 18 of 40 IU Name Category Address Comments IU Name Category Address Comments IU Name Category Address Comments IU Name Category Address Comments SECTION IX: INDUSTRIAL USER FILE EVALUATION United Dairy, Inc. N/A PWF4 55,800 GPD avg. est.* 508 Roane St. Charleston, WV 25302 (Permit #109) *Flow at this IU is not monitored or recorded. PWF is estimated for manhole where the majority of process wastewater flows. (IU1) City of Charleston Sanitary Landfill (operated by Waste Management) N/A PWF6 68,409 GPD avg. 741 S Park Rd., Charleston, WV 25304 (Permit #111) (IU2) Charleston Area Medical Center General Hospital N/A 501 Morris St., Charleston, WV 25336 (Permit #107) (IU3) PWF6 100,788 GPD avg. Charleston Area Medical Center Memorial Hospital N/A 3200 MacCorkle Ave, SE, Charleston, WV 25304 (Permit #106) (IU4) PWF6 242,600 GPD avg. 4 Process waste flow 19 of 40 NOTE: Complete all questions with a "Y" (yes), "N" (no), "N/A" (not applicable), "U" (unable to determine), the appropriate number, or as directed in the question. Note that a copy of a typical permit should be obtained for the complete permit form review which is done separately and included as an attachment to the report. FILE REVIEW CHECKLIST A1. Industrial User Characterization IU1 IU2 IU3 IU4 1. Is the IU categorical (CIU), non-significant categorical (NSCIU), middletier categorical (MTCIU), significant non-categorical (SNIU) or other (O)? SNIU SNIU SNIU SNIU 2. Is the IU properly categorized? N/A N/A N/A N/A A2. Non-Significant Categorical Industrial Users (complete past #1 only if the user is designated as an NSCIU) 1. Has the user been designated as an NSCIU? N N/A N N 2. If yes, is there documentation in the file that shows that the user: never discharges more than 100 gpd of categorical wastewater? N/A N/A N/A N/A never discharges any untreated concentrated wastewater? N/A N/A N/A N/A consistently complied with all applicable pretreatment standards and N/A N/A N/A N/A requirements prior to and since the designation? 3. Has the user submitted the annual certification required by 403.12(q)? NA N/A N/A N/A 4. Are certifications signed by a responsible corporate official or authorized representative? NA N/A Y Y5 5. If applicable, was the authorization made in writing? NA N/A N/A N/A A3. Middle-Tier Categorical Industrial Users (complete past #1 only if the user is designated as a MTCIU) 1. Has the user been designated as a MTCIU? N/A N/A N/A N/A 2. If yes, is there documentation in the file that shows that: the user's total categorical wastewater flow does not exceed: N/A N/A N/A N/A - 0.01% of the dry weather hydraulic capacity of the POTW or 5000 gpd whichever is smaller? N/A N/A N/A N/A if yes, is the flow determination based on a continuous effluent N/A N/A N/A N/A flow monitoring device? - 0.01% of the design dry weather organic treatment capacity of the POTW? N/A N/A N/A N/A - 0.01% of the MAHL for any categorical pollutant? N/A N/A N/A N/A 5 SMR was received electronically. 20 of 40 FILE REVIEW CHECKLIST the user has not been in SNC since at least two years prior to its designation as a MTCIU? the user does not have flow rates, production levels, or pollutant levels that vary so significantly that the MTCIU designation is inappropriate? IU1 IU2 IU3 IU4 N/A N/A N N N/A N/A N/A N 3. Has the documentation been maintained for at least three years after N/A N/A Y Y expiration of the control mechanism? B. Application of Standards 1. Were local limits and/or categorical standards properly applied? N6 N7 N8 N 2. If applicable, were production-based standards correctly applied? NA N/A N/A N/A 3. If applicable, was the combined wastestream formula correctly applied? N/A N/A N/A N/A 4. If applicable, were TTO requirements or alternatives correctly applied? N/A N/A N/A N/A 5. Does the control mechanism include BMPs in place of local limits? Y9 N N/A Y If yes, is the BMP authorized in the POTW ordinance? Y10 N/A N/A Y C1. Control Mechanism (also obtain a copy of a typical permit for the permit form review) 1. Does the file contain: an updated control mechanism application and/or survey questionnaire? Y11 Y Y Y a current control mechanism? Y Y Y Y documentation12 of how control mechanism limits and requirements N N N N were established? 2. Is the user regulated through an individual control mechanism (ICM) or ICM ICM ICM ICM general control mechanism (GCM)? 6 The limits included on page 2 of the IU permit do not match with the local limits listed on the SUO. 7 Limits in the SUO are not found in the permit. 8 The SUO includes oil and grease. The POTW does not sample oil & grease. 9 In the form of specific prohibitions and other narrative effluent limitations listed in part 1 of the IU permit. 10 See section 118-203 of SUO, prohibitions and limitations on wastewater discharges. 11 Permit cover letter should contain any applicable procedures for appealing the permit conditions. 12 Categorization, new source, combined wastestream formula, production-based standards, monitoring frequency, comparison of local limits to categorical standards, etc. 21 of 40 FILE REVIEW CHECKLIST IU1 IU2 IU3 IU4 3. Does the control mechanism include: limits for all categorical and local limit pollutants? N13 N N N all applicable slug control requirements? N14 ?15 N/A Y all applicable BMP requirements? N/A N/A N/A Y monitoring requirements for all categorical and local limit pollutants? N16 N N/A N - if no, is there documentation of the reasons for excluding specific pollutants? N17 N N/A N sampling location and frequency? Y18 Y N/A Y19 sample type, including appropriate use of grab and composite samples? Y/N20 Y N/A Y - if used, is there documentation on the use of time-proportional or grab samples in place of flow-proportional samples? ? N N/A N if the user is an MTCIU, the requirement for notification of changes causing it to no longer meet the MTCIU criteria? N/A N/A N/A N/A a compliance schedule? N/A N N/A N - if yes, does it stay applicability of permit requirements? N/A N/A N/A N/A 4. Is the permit effective for 5 years or less? Y Y N/A Y 13 The limits from Charleston's SUO are not in the permit other than oil & grease. Part I, B, tables 1-3 reference part II b for reporting requirements. This seems in error as part b references resampling in the event of a violation and not reporting to the POTW. 14 40 CFR 403.8(f)(2)(vi) requirements of a slug control plan. As United Dairy has the potential to send a slug to the POTW, Charleston should require United Dairy in the permit to have a slug control plan. 15 Immediate notification only. 16 The Charleston SUO has limits for mercury, benzene, toluene, ethylbenzene, xylene and PAHs, all of which are not required to be monitored in the permit. 17 No permit background information could be found to justify the reduced/no monitoring for these pollutants. 18 The application from United Dairy indicates floor drains from chemical storage discharge to "manhole 2". The slug plan addresses chemicals from storage; are these them? Are they plugging this floor drain? Has United Dairy ever had a spill of chemicals down this drain; has the POTW considered different monitoring parameters for this specific sampling location? 19 Permittee is authorized to discharge to 6 manholes, but limits only apply to two sampling points. Not all discharge points being monitored. 20 The permit only indicates, "grab samples shall consist of four separate samples during hours of production" and "composite samples shall be collected during hours of production". These sampling instructions are not clear enough and do not indicate whether the grabs/composite are flow or time proportioned. The permit should clearly indicate the intervals of sampling. 22 of 40 FILE REVIEW CHECKLIST IU1 IU2 IU3 IU4 5. In the inspector's opinion, is the sample frequency sufficient to determine compliance? Y Y N/A Y C2. General Control Mechanism (complete past #1 only if the user has been issued a general control mechanism) 1. Is the user covered by a general control mechanism? N/A N/A N/A N/A 2. If yes, does POTW documentation include: copy of general permit? N/A N/A N/A N/A user's request for coverage? N/A N/A N/A N/A demonstration that user meets eligibility criteria including: - similar types of operations as other covered users? N/A N/A N/A N/A - same types of waste as other covered users? N/A N/A N/A N/A - same effluent limits as other covered users? N/A N/A N/A N/A - same or similar monitoring as other covered users? N/A N/A N/A N/A - user not subject to production-based standards, mass-based standards, CWF, or net gross variance? N/A N/A N/A N/A demonstration that user appropriately covered by general permit? N/A N/A N/A N/A 3. Has the documentation been maintained for at least 3 years after expiration of the control mechanism? N/A N/A N/A N/A 4. Did the user file a written request for coverage that identified its: contact information? N/A N/A N/A N/A production processes? N/A N/A N/A N/A types of waste generated? N/A N/A N/A N/A monitoring location? N/A N/A N/A N/A C3. Equivalent Mass Limits (complete past #1 only if the user has been issued equivalent mass limits in place of concentration based categorical standards) 1. Has the user been issued equivalent mass limits in place of concentration based categorical standards? N/A N/A N/A N/A 2. If yes, has the POTW issued mass limits only for pollutants for which mass limits are appropriate (excludes pH, temperature, radiation, and other similar pollutants)? N/A N/A N/A N/A 3. Did the user submit documentation that establishes: that it employs water conservation? N/A N/A N/A Y 23 of 40 FILE REVIEW CHECKLIST IU1 IU2 IU3 IU4 that it uses treatment adequate to achieve compliance? N/A N/A N/A Y that it does not use dilution? N/A N/A N/A N the average daily flow based on monitoring? N/A N/A N/A Y the long-term production rate? N/A N/A N/A N/A that its flow, production, and pollutant levels do not vary significantly? N/A N/A N/A N that it has consistently complied with categorical standards? N/A N/A N/A N/A 4. Were limits calculated based on actual average daily flow? N/A N/A N/A N/A 5. Did the POTW reassess the limits based on changes in production? N/A N/A N/A N/A 6. Were mass limits retained in subsequent control mechanisms? N/A N/A N/A N/A If yes, was there a change in average flow from the previous control mechanism? N/A N/A N/A N/A - If yes, is there documentation that the flow reduction was solely the N/A N/A N/A N/A result of water conservation? 7. Is there documentation in the file that demonstrates that the user: has maintained and operated its treatment equipment? N/A N/A N/A Y/N21 uses continuous flow monitoring? N/A N/A N/A N records and reports production rates? N/A N/A N/A N has provided notification where production rates have varied by more than 20% from the production rate used at the time that the mass N/A N/A N/A N/A limits were established? continues to employ water conservation? N/A N/A N/A Y C4. Equivalent Concentration Limits (complete past #1 only if the user has been issued equivalent concentration limits in place of mass based categorical standards) 1. Has the user been issued equivalent concentration limits in place of mass based categorical standards? N/A N/A N/A N 2. If yes, is the user subject to a categorical standard other than 40 CFR 414, 419, or 455? N/A N/A N/A N/A 3. Does the control mechanism include the concentration limits from the N/A N/A N/A N categorical standard? 4. Is there documentation that the user does not use dilution? N/A N/A N/A N/A 21 IR did not discuss maintenance of pH neutralization pretreatment system. 24 of 40 FILE REVIEW CHECKLIST IU1 IU2 IU3 IU4 C5. Pollutants Not Present (complete past #1 only if the user has been granted a monitoring waiver for pollutants not present) 1. Has the user has been granted a monitoring waiver for pollutants not present for any pollutants regulated by an applicable categorical N/A N/A N/A N standard? 2. If yes, has the user demonstrated through sampling and other technical N/A N/A N/A N/A factors that the pollutant is neither present nor expected to be present? 3. Does the user's request for the waiver include: at least one sample result prior to treatment that is representative of N/A N/A N/A N/A all process wastestreams? use of non-detectable results only where the approved test method with the lowest detection level is used? N/A N/A N/A N/A appropriate signature and certification? N/A N/A N/A N/A 4. Is the waiver included in the user's control mechanism? N/A N/A N/A N/A 5. Is the waiver valid for no longer than the user's current control mechanism? N/A N/A N/A N/A 6. Does the control mechanism require the user to: notify the POTW if the pollutant is found or expected to be present? N/A N/A N/A Y begin at least semiannual monitoring if pollutant is found or expected N/A N/A N/A N to present? 7. Has the user reapplied for the waiver with each subsequent control mechanism application, including new data? N/A N/A N/A N/A 8. Has documentation of the granting of the waiver been maintained for at least 3 years after expiration of the waiver? N/A N/A N/A N/A 9. Has the user submitted the required certification with each selfmonitoring report? N/A N/A N/A N/A D. POTW Inspections of IUs 1. How many POTW inspections were conducted and documented in the 1 last 12 months? 1 N/A 1 2. Does the inspection report include: inspector name? Y N22 N/A Y 22 Initials only. 25 of 40 FILE REVIEW CHECKLIST IU1 IU2 IU3 IU4 inspection date/time? N N23 N/A N24 name of IU official contacted? Y Y N/A Y evaluation of manufacturing facilities? Y Y N/A Y evaluation of discharge of process baths or other chemicals? Y Y N/A N/A verification of production data if needed? N/A N/A N/A N/A identification of wastewater sources, flow and types25 of discharge? Y Y N/A Y evaluation of pretreatment facilities? Y Y N/A Y evaluation of chemical storage areas? Y/N26 N/A N/A Y evaluation of spill/slug control procedures? Y27 Y N/A Y if applicable, evaluation of compliance with BMPs? N28 N/A N/A Y evaluation of general housekeeping? Y/N Y N/A N potential hazardous waste discharge? N29 N N/A Y evaluation of self-monitoring equipment and techniques? N Y N/A Y evaluation of lab procedures? N N/A N/A N/A evaluation of monitoring records? N Y N/A Y E. POTW Sampling of IUs 1. How many sampling visits were conducted and documented in the last 630 1 N/A 1 12 months? 23 Only date, no time. 24 Time is missing. 25 Continuous, intermittent, batch, etc. 26 The inspection report mentions it but does not list chemicals stored on site. Inspector should verify this with what United Dairy has previously submitted as part of their slug/spill plan. 27 CSB made note of the need for slug plan and that the facility has it. The POTW should note, they are required to verify the slug plan contains requirements in 40 CFR 403.8(f)(2)(vi). 28 No BMPs in the permit. Could be beneficial to have BMPs considering the recent slug to the plant. Eg. https://www.epa.gov/system/files/documents/2021-07/pretreatment_streamlining_7.0.pdf 29 Chemical storage? 30 Where they were supposed to have monthly sampling reports, looks like they did not upload the compliance sampling reports from March, Sep, Oct, Nov, Dec; large group of limited pollutants at MH1-4 had sampling frequency of 1x/month. 26 of 40 FILE REVIEW CHECKLIST 2. Do the sampling reports include: all analytical results? name of sampling personnel? sample date/time? sample type? sample location? wastewater flow during sampling? sample preservation? chain of custody? analytical methods used? analysis date? name of analyst? 3. Were all regulated parameters monitored? 4. Were 40 CFR 136 analytical methods used? 5. If POTW does not require self-monitoring, has the POTW resampled within 30 days after a violation? IU1 IU2 IU3 IU4 Y Y N/A Y31 Y32 N33 N/A Y Y Y N/A Y Y Y N/A Y ?34 Y N/A Y ? N N/A N ? Y N/A Y Y35,36 Y37 N/A Y Y Y N/A Y Y Y N/A Y ?38 Y N/A N N/A Y N/A Y N/A Y N/A Y NA N/A N/A N/A F. IU Self-Monitoring and Reporting 1. Has the IU submitted all required self-monitoring reports in the last 12 N39 Y Y Y months? 2. Did the report include measured or estimated flow data? N Y N N 31 MH1 and MH2 had different limitations. Mercury report only was not required for MH2. 32 A couple of information points that were missing on the lab sheets. 33 Initials only. 34 Indicates which MH was sampled, MH locations on map within the sampling guidance. 35 Chain of custody could use modification - only signature or initials of sampler. No name. 36 Chain of custody will only indicate whether samples were preserved or not; does not detail what the preservation method was. 37 Just signatures, no written names or titles. 38 Only initials available, not enough information to know who analyst is. 39 Only received 6 out of 12 analytical reports. 27 of 40 FILE REVIEW CHECKLIST 3. Were all regulated parameters monitored at the required frequency? IU1 IU2 IU3 IU4 ?40 Y N41 Y 4. If applicable, was information provided to determine compliance with applicable BMPs? N N/A N/A N/A 5. Is there documentation that the IU notified the POTW within 24 hours N of becoming aware of a violation? Y N/A N/A 6. Has the IU resampled and reported within 30 days after a violation? Y Y Y N/A 7. Are reports signed and certified by a responsible corporate official or Y Y Y Y authorized representative? 8. If applicable, was the authorization made in writing? Y42 N/A N/A N/A G. Slug/Spill Control 1. Is there documentation in the file that the POTW conducted a slug Y evaluation? 2. If yes, does it include an inventory of process baths and other chemicals on site along with an evaluation of the potential for discharge of those Y baths and chemicals? 3. Have any slugs/spills been documented in the file? Y 4. If yes, did the user provide 24-hour notification? ? 5. Was there a written report from the user addressing the slug/spill Y including: cause of the slug/spill? Y steps taken to minimize damage from the slug/spill? Y steps taken to ensure that the slug/spill does not recur? Y 6. Did the POTW require development of a slug/spill control plan? Y 7. Has the IU developed a slug/spill control plan? Y 8. Does the slug/spill plan contain: description of discharge practices? Y description of stored chemicals? Y Y N/A Y Y N/A Y N N/A N N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Y N/A Y Y N/A Y Y N/A N Y N/A Y 40 Difficulty understanding lab reports, so unsure if pollutants with monthly monitoring frequency requirements had samples taken at the right frequencies. 41 SUO states oil and grease will be sampled, this did not transfer over to the control mechanism. 42 Certification statement and signature by authorized representative on the report. 28 of 40 FILE REVIEW CHECKLIST procedures to prevent slugs/spills? procedures to notify POTW of slugs/spills? follow-up practices to minimize damage from slugs/spills? H. Enforcement 1. Did the POTW respond to all IU violations in the last 12 months? 2. Was SNC status correctly reported on last AR? 3. Is the IU currently in SNC? 4. Is the IU under a formal enforcement action? 5. Did the POTW escalate action in accordance with the ERP? I. Summary 1. Is the file well organized and readily accessible? 2. Does the file indicate that the POTW has implemented only those streamlining options for which it has obtained approval? IU1 IU2 IU3 IU4 Y Y N/A Y Y Y N/A N Y Y N/A N Y N/A N/A N/A Y Y N/A Y Y43 N N/A N Y44 N N/A N Y N/A N/A N/A Y Y N/A Y Y Y N/A Y 43 Difficult to tell from the SNC documentation during what period United Dairy fell into SNC. Understood from Audit interview that SIU was no longer in SNC. 44 Issued NOVs and monetary penalties. 29 of 40 SECTION X: FINDINGS, REQUIREMENTS, AND RECOMMENDATIONS A. LEGAL AUTHORITY (City of Charleston, West Virginia Code of Ordinances, II.118(III)(6)) Attachment 1 provides the full "POTW Legal Authority Review Checklist". Whether a finding is required or recommended can be differentiated in this attachment. Refer to the following for sewer use ordinance required and recommended language: EPA Model Pretreatment Ordinance o https://www3.epa.gov/npdes/pubs/pretreatment_model_suo.pdf 40 CFR 403.8(f)(1) o https://www.ecfr.gov/current/title-40/chapter-I/subchapter-N/part-403#p403.8(f)(1) Term or Topic "Approval Authority" "Composite Sample" "Industrial User" "National Pretreatment Standard, Pretreatment Standard, or Standard" "POTW" "Pretreatment" Finding Corrective Action A. Definitions Inconsistent Correct "Approved Authority" to "Approval Authority" Absent Add "Composite Sample" Inconsistent Correct to "A source of indirect discharge" Inconsistent Correct to "Prohibited discharge standards, categorical Pretreatment Standards, and Local Limits" Inconsistent Correct to "A treatment works, as defined by section 212 of the Act (33 U.S.C. section 1292), which is owned by the Board. This definition includes any devices or systems used in the collection, storage, treatment, recycling, and reclamation of sewage or industrial wastes of a liquid nature and any conveyances, which convey wastewater to a treatment plant." Inconsistent Correct to " The reduction of the amount of pollutants, the elimination of pollutants, or the alteration of the nature of pollutant properties in wastewater prior to, or in lieu of, introducing such pollutants into the POTW. This reduction or alteration can be obtained by physical, chemical, or biological processes; by process changes; or by other means, except by diluting the concentration of the pollutants unless allowed by an applicable Pretreatment Standard." 30 of 40 "Pretreatment Requirement" "Significant Industrial User" Toxic Gases/Vapor/Fumes Development of BMPs as local limits and Pretreatment Standards Individual and General Control Mechanism (e.g., permit) to ensure compliance Absent Add "Pretreatment Requirement means any substantive or procedural requirement related to pretreatment imposed on a User, other than a Pretreatment Standard." Inconsistent Correct to " (1) An Industrial User subject to categorical Pretreatment Standards; or (2) An Industrial User that: (a) Discharges an average of twenty-five thousand (25,000) gpd or more of process wastewater to the POTW (excluding sanitary, noncontact cooling and boiler blowdown wastewater); (b) Contributes a process wastestream which makes up five (5) percent or more of the average dry weather hydraulic or organic capacity of the POTW treatment plant; or (c) Is designated as such by the Board on the basis that it has a reasonable potential for adversely affecting the POTW's operation or for violating any Pretreatment Standard or Requirement." B. Prohibited Discharges Absent Add "Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity that may cause acute worker health and safety problems;" Absent Add "The Board may develop Best Management Practices (BMPs), by ordinance or in individual wastewater discharge permits, to implement Local Limits and the requirements of Section 118-203." (only if authorized under State law) C. Permit Conditions Typo Correct "into the without" to "into the POTW without" at 118-206(b). 31 of 40 General/Specific Inconsistent Add the toxic gases, vapor, fumes specific Prohibitions prohibition (40 CFR 403.5(b)(7)) to both the SUO and the industrial user discharge permit form template. D. Require Development of Compliance Schedule and Reporting Requirements Baseline monitoring Absent Add baseline monitoring report language to the report SUO (Model SUO 6.1 and 40 CFR 403.12). 90-day compliance Inconsistent Correct to the language of Model SUO 6.3 where report for categorical required. Pretreatment Standards Periodic reports on Absent Add the language of Model SUO 6.4 where continue compliance required. Notification of discharge Absent Add the language of Model SUO 6.9. of hazardous waste Recordkeeping Inconsistent Correct to the language of Model SUO 6.13. Requirement (3 years or longer) Submission of all Absent Add "If a User subject to the reporting requirement monitoring data in this section monitors any regulated pollutant at the appropriate sampling location more frequently than required by the Board using the procedures prescribed in Section 118-209(c)(1), the results of this monitoring shall be included in the report." Upset Provisions Inconsistent Correct "applicable discharge standard or requirement" to "categorical Pretreatment Standards". Bypasses and Inconsistent Correct "the User" to "it" and remove "one or more Notification of". G. Remedies for Noncompliance (Enforcement) Enforcement Response Absent Add "Enforcement of pretreatment violations will Plan incorporated into generally be in accordance with the Board's legal authority enforcement response plan" required to be developed following the finding below. 32 of 40 B. APPLICATION OF STANDARDS 1. 40 CFR 403.18 requires procedures for the approval of substantial and non-substantial program modifications by the Approval Authority (WVDEP). FINDING: (1) Local limits in the SUO have not been formally approved by the WVDEP, nor (2) have substantial modification requests been formally approved by the WVDEP; therefore, it is REQUIRED that CSB initiate any and all program modifications, such as those relating to its local limits, pursuant to procedures listed at 40 CFR 403.18. 2. 40 CFR 403.8(f)(1)(iii)(B) requires that control mechanisms must be enforceable and contain, at a minimum the conditions highlighted under that citation. The provisions highlighted in 40 CFR 403.8(f)(1)(iii)(B)(3) specifically highlights the need for inclusion of effluent limits in individual/general control mechanisms. FINDING: CSB applies limitations within industrial user discharge permits with no justification or reference to an approved local limit (or other standard) within the SUO; therefore, it is REQUIRED that CSB either (1) pursue modification of its existing local limits to include these limitations that do not have an established technical basis, justification or reference, or (2) remove those limitations that do not have a technical basis, justification or reference. 3. 40 CFR 403.5(c)(2) requires POTWs with approved pretreatment programs to develop specific limits"in cases where pollutants contributed by User(s) result in Interference or Pass-Through, and such violation is likely to recur, develop and enforce specific effluent limits for Industrial User(s), and all other users, as appropriate, which together with appropriate changes in the POTW Treatment Plant's facilities or operation, are necessary to ensure renewed continued compliance with the POTW's NPDES permit or sludge use or disposal activities". FINDING: Pollutants that have caused or contributed to pass-through or interference do not maintain specific limits in the appropriate industrial user discharge permits; therefore, it is REQUIRED that CSB pursue modification of its existing local limits to include specific limits for pollutants which have historically caused pass-through or interference at the POTW. CSB should generally conduct an evaluation of the need for numerical local limits for pollutants, such as BOD5 and TSS, and whether they are necessary. 4. FINDING: The industrial user discharge permits reviewed were found to not include a specific limitation for, or a requirement of "monitor only", for certain local limits with maximum allowable industrial loadings; therefore, it is RECOMMENDED that CSB minimally reallocate its existing local limits maximum allowable industrial loadings where not done so. This should avoid technical violation (above a loading of "0 lbs/day") of limits for those pollutant parameters with loadings of "0 lbs/day". 33 of 40 5. FINDING: CSB does not document the allocation of local limits maximum allowable industrial loadings; therefore, it is RECOMMENDED that CSB maintain a document or spreadsheet outlining how the local limits maximum allowable industrial loadings (MAIL) are allocated to all the significant industrial users permitted by CSB in order to ensure the MAIL is not exceeded. 6. 40 CFR 266.505 prohibits "discharging hazardous waste pharmaceuticals to a sewer system that passes through to a publicly-owned treatment works" by "[a]ll healthcare facilities". FINDING: While CSB prohibits the discharge of "medical wastes" in industrial user discharge permits covering respective healthcare facilities, it is RECOMMENDED that CSB revise this condition in these permits to reflect the language of this prohibition. Such as defining "medical wastes" to include "hazardous waste pharmaceuticals". C. CONTROL MECHANISM Attachment 3 provides the full "Permit Form Review" for the industrial user discharge permit issued to United Dairy, Inc. Whether a finding is required or recommended will be identified in this attachment. Where applicable, the corrective actions noted above should also be corrected in the United Dairy, Inc. industrial user discharge permit. Refer to the following for individual control mechanism required and recommended language: Sample Permit Fact Sheet and Industrial User Permit o https://www.epa.gov/system/files/documents/202107/appendix_e_samplepermitfactsheetandpermit_2012.pdf 40 CFR 403.8(f)(1)(iii)(B) o https://www.ecfr.gov/current/title-40/chapter-I/subchapter-N/part-403#p403.8(f)(1)(iii)(B) 34 of 40 Topic Does the permit identify the specific wastestreams authorized for discharge? Notification of appeal rights? Effluent limits including all local limits? Slug control requirements? All prohibitions included? Upset & bypass consistent with ordinance and 40 CFR 403? BMP compliance reports? Notification of facility change affecting slug discharge potential? BMP compliance information? Hazardous waste notification? Right of entry? Non-transferability? Dilution prohibition? Finding Absent Absent Inconsistent Absent Inconsistent Absent Absent Absent Absent Absent Absent Inconsistent Absent Corrective Action Add Add Refer to Section X., Subsection B. Application of Standards. Add [Cite: 40 CFR 403.8(f)(1)(iii)(B)(6)] Revise "8. TOXIC SUBSTANCES: Any toxic substance in amounts exceeding standards promulgated by the Administrator of the United States Environmental Protection Agency pursuant to Section 307(a) of the Clean Water Act, and chemical elements or compounds, phenols or other taste or odor producing substances, or any other substances which are not susceptible to treatment or which may interfere with the biological process or efficiency of the POTW, or that will pass through the treatment plant, and any substances which may cause acute worker health and safety problems." [Cite: 40 CFR 403.5(b)(7)] Add [Cite: 40 CFR 403.16 and 40 CFR 403.17] Add, where applicable [Cite: 40 CFR 403.8(f)(2)(viii)(F)] Add [Cite: 40 CFR 403.8(f)(2)(vi)] Add, where applicable [Cite: 40 CFR 403.5(c)-(d)] Add [Cite: 40 CFR 403.12(p)] Add [Cite: 40 CFR 403.8(f)(1)(iv),(v),(vii)] Add "A copy of the existing permit shall be provided to the new owner or operator." [Cite: 40 CFR 403.8(f)(1)(B)(2)] Add [Cite: 40 CFR 403.6(d)] 35 of 40 Representative sampling? Absent Add [Cite: 40 CFR 403.12(g)(3)] 1. FINDING: Based on observations made at the inspection of United Dairy, Inc., it is REQUIRED that CSB incorporate good housekeeping practices in the industrial user discharge permit issued to United Dairy, Inc. Per 40 CFR 403.5(c)(4), a POTW may develop Best Management Practices to implement 40 CFR 403.5(c)(1) and 40 CFR 403.5(c)(2). At the closing conference with United Dairy, Inc., the facility was instructed to implement general housekeeping (such as emptying spill containment pallets, cleaning chemical spills, etc.) by February 9, 2023. CSB should inform EPA of the facility's progress, including (1) the sealing of drains located in chemical storage areas, (2) the posting of notification procedures for spills, (3) the spill prevention plan being made readily available to personnel, (4) monthly pH sampling training being conducted, (5) the installation of a flow meter at MH2, and (6) the installation of a heat exchanger at MH4. D. COMPLIANCE MONITORING 1. 40 CFR 403.8(f)(2)(v) requires that POTWs with approved pretreatment programs shall develop and implement procedures to ensure compliance with the requirements the federal regulations. At a minimum, these procedures include 40 CFR 403.8(f)(2)(v) "[i]nspect and sample the effluent from each Significant Industrial User at least once a year". FINDING: CSB has not been conducting independent monitoring at the City of Charleston Sanitary Landfill and CAMC Memorial Division. CSB does not hold a copy of the key for the lock that secures the gate for the access road leading to the monitoring location at the City of Charleston Sanitary Landfill. Further, the monitoring location at the CAMC Memorial Division is beneath a vehicle parking space, which can be obstructed. By not having access to the monitoring locations at all times, independent monitoring by the POTW cannot be verified as the sampling location as the sampling location should be accessible at all times; therefore, it is REQUIRED that CSB make arrangements with the City of Charleston Sanitary Landfill and CAMC Memorial Division to ensure complete and 24/7 access to the respective monitoring locations. 2. 40 CFR 403.8(f)(2)(v) requires that POTWs shall "[r]andomly sample and analyze the effluent from Industrial Users". FINDING: CSB does not conduct sampling at all significant industrial user outfalls; therefore, per 40 CFR 403.8(f)(2)(v), it is REQUIRED that CSB sample and analyze the effluent from all points where the industrial user is connected to the collection system, where possible and where appropriate. 36 of 40 3. 40 CFR 403.12(o)(1) requires that Any Industrial User and POTW subject to the reporting requirements established in this section shall maintain records of all information resulting from any monitoring activities . . . Such records shall include for all samples: (i) The date, exact place, method, and time of sampling and the names of the person or persons taking the samples; (ii) The dates analyses were performed; (iii) Who performed the analyses; (iv) The analytical techniques/methods use; and (v) The results of such analyses. FINDING: The industrial user inspection reports reviewed were found to include (1) the initials only of the inspector, and (2) the date only of the inspection; (3) the initials only of the sampler on the industrial user sampling reports; and (4) the signatures only of the custodians on the chain of custody forms; therefore, it is REQUIRED that CSB revise its procedures and forms to include (1) the name(s) of the inspector(s), (2) the time of the inspection, (3) the name of the sampler, and (4) the name and title of sample custodians. While initials and signatures may be easily identifiable to CSB, adding this information allows for clarity in case of an audit by WVDEP or EPA, or by a request for information from the public. 4. 40 CFR 403.8(f)(2)(v) requires that POTWs shall "[r]andomly sample and analyze the effluent from Industrial Users". FINDING: CSB conducts monitoring activities at United Dairy, Inc. on a regular schedule; therefore, it is RECOMMENDED that CSB randomize its schedule for monitoring activities at United Dairy, Inc., and all other significant industrial users. Monitoring activities on a random basis encourage industrial user managers to keep their operations in continual compliance, not only when an inspection or regular sampling event is expected. 5. 40 CFR 403.12(o)(1) requires that POTWs shall "maintain records of all information resulting from any monitoring activities". FINDING: CSB does not substantially document monitoring activities not considered as part of the minimum annual inspection for United Dairy, Inc.; therefore, it is REQUIRED that CSB, in addition to its existing log of meeting with United Dairy, Inc., record any and all meetings with this industrial user or any other industrial users. 37 of 40 6. FINDING: The Audit Team noted historical and significant variations in BOD5 reported on the DMRs for United Dairy, Inc.; therefore, it is RECOMMENDED that CSB continue to monitor for any further significant variations, and if these variations are persistent, determine appropriate limitations. As discussed previously, CSB should conduct an evaluation of the need for numerical local limits for conventional pollutants, such as BOD5, TSS, Ammonia Nitrogen and whether they are necessary. E. ENFORCEMENT 1. 40 CFR 403.8(f)(5) requires that POTWs shall "develop and implement an enforcement response plan. This plan shall contain detailed procedures indicating how a POTW will investigate and respond to instances of industrial user noncompliance. The plan shall, at a minimum: (i) Describe how the POTW will investigate instances of noncompliance; (ii) Describe the types of escalating enforcement responses the POTW will take in response to all anticipated types of industrial user violations and the time periods within which responses will take place; (iii) Identify (by title) the official(s) responsible for each type of response; (iv) Adequately reflect the POTW's primary responsibility to enforce all applicable pretreatment requirements and standards, as detailed in 40 CFR 403.8 (f)(1) and (f)(2)." FINDING: CSB does not maintain a formal enforcement response plan; therefore, it is REQUIRED that CSB develop and implement an enforcement response plan in accordance with those minimum components above. This plan should be submitted to the approval authority (WVDEP) for review and approval. The Guidance for Development Control Authority Enforcement Response Plans document (https://www.epa.gov/system/files/documents/2021-07/owm0015.pdf) is available as a guide for all POTWs. 2. 40 CFR 403.8(f)(1)(iii)(B)(3) requires that control mechanisms must be enforceable and contain, at a minimum, and among others at this citation, "[e]ffluent limits, including Best Management Practices". FINDING: It was noted during the on-site visit of United Dairy, Inc. that CSB accepts prohibited discharge associated with a Best Management Practice ("[t]he discharge of milk or milk products into the POTW is prohibited without prior approval from CSB"), specifically residue from milk solids; therefore, it is REQUIRED that CSB ensure that this permit narrative is enforced, or revise it based on existing conditions at United Dairy, Inc. 38 of 40 F. DATA MANAGEMENT AND PUBLIC PARTICIPATION 1. 40 CFR 403.8(f)(2)(i) requires that POTWs shall "[i]dentify and locate all possible Industrial Users which might be subject to the POTW Pretreatment Program." 40 CFR 403.3(v)(1) states that "the term Significant Industrial User means: All Industrial Users subject to Categorical Pretreatment Standards" and "[a]ny other Industrial User that: discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary, noncontact cooling and boiler blowdown wastewater); contributes a process wastestream which makes up 5 percent or more of the average dry weather hydraulic or organic capacity of the POTW Treatment plant; or is designated as such by the Control Authority on the basis that the Industrial User has a reasonable potential for adversely affecting the POTW's operation or for violating any Pretreatment Standard or requirement". FINDING: CSB may not be identifying possible categorical industrial users which might be subject to the POTW pretreatment program standards; therefore, it is REQUIRED that CSB revise its existing industrial waste survey procedures and/or industrial waste inventory to (1) assess and address potential industrial users that are subject to Categorical Pretreatment Standards regardless of if they may discharge an average of 25,000 gallons per day or more of process wastewater to the POTW, and (2) reflect the interpretation of "per day" of the "average of 25,000 gallons per day or more" being those days that the potential industrial user actually discharges--not considering those days that it does not. The average discharge from a facility is based on the number of discharge days and not on calendar days or even production days. For example, if a facility discharges 25,000 gallons once a week, it would be considered a significant industrial user pursuant to 40 CFR 403.3(v)(1)(ii). 2. 40 CFR 403.12(l) requires that reports submitted by industrial users "shall be signed". Under current interpretation, a signed report means those with a certified, nonelectronic, "wet" ink signature. Pursuant to 40 CFR 3.1000(a), "[a] state, tribe, or local government that receives or plans to begin receiving electronic documents in lieu of paper documents to satisfy requirements under an authorized program must revise or modify such authorized program to ensure that it meets the requirements of [40 CFR Part 3, Subpart D]". FINDING: CSB accepts periodic reports from certain industrial users primarily in electronic format without CROMERR approval; therefore, it is REQUIRED that CSB accept the submittal of reports in paper format until such time that CSB is approved under the Cross-Media Electronic Reporting Rule (CROMERR). Note, CSB may receive electronic submissions so long as they are duplicative to an original paper format with "wet" ink signature where necessary. For more information on CROMERR, you may navigate to: https://www.epa.gov/cromerr 39 of 40 3. 40 CFR 441.50(a) requires "[f]or existing [Dental Discharger] sources, a One-Time Compliance Report must be submitted to the Control Authority no later than October 12, 2020, or 90 days after a transfer of ownership. For new sources, a One-Time Compliance Report must be submitted to the Control Authority no later than 90 days following the introduction of wastewater into a POTW". FINDING: CSB maintains a list of dental discharges but has not maintained records of one-time compliance reports submitted by dental dischargers subject to 40 CFR part 441; therefore, it is REQUIRED that CSB clarify if it is compliant with those Dental Effluent Guidelines at 40 CFR Part 411. 4. FINDING: The industrial waste survey inventory that CSB maintains does not detail additional information beyond the names of the respective facilities; therefore, it is RECOMMENDED that CSB provide further detail to its existing and future industrial waste survey inventories, such as addresses, simple justification for why CSB determined the facility to not be subject to the POTW pretreatment program, etc. Attachments Attachment 1 Attachment 2 Attachment 3 Attachment 4 Attachment 5 POTW Legal Authority Review Checklist File Review Worksheets 2.1 - United Dairy, Inc. 2.2 - City of Charleston Sanitary Landfill 2.3 - Charleston Area Medical Center General Hospital 2.4 - Charleston Area Medical Center Memorial Hospital Permit Form Review United Dairy, Inc. Industrial Inspection Reports 4.1 - United Dairy, Inc. 4.2 - City of Charleston Sanitary Landfill Audit Action Items Checklist 40 of 40 NAME OF POTW: NPDES # DATE OF REVIEW: MUNICIPAL ORDINANCE CITATION: Attachment 1: POTW LEGAL AUTHORITY REVIEW CHECKLIST The Sanitary Board of the City of Charleston, West Virginia WV0023205 1/20/2023 City of Charleston, West Virginia, Code of Ordinances, Part II; Chapter 118 - Utilities; Article III - Sewers and Sewage Disposal; Division 6 - Discharge Restrictions OK = No revision necessary REC = Recommend Revision REQ = Revision Required Part 403 Cite OK Absent or POTW Legal Authority REC REQ needs mod Section Mod Mod Purpose/Objective 403.1 Act, Clean Water Act Approval Authority Authorized Representative of the IU BMPs Categorical Standards - Parts 405471, 40 CFR chapter I, subchapter N. . Categorical Industrial User Composite Sample Control Authority Grab Sample Indirect Discharge (b),(c),(d) Industrial User (or equivalent) Interference 403.3(b) 403.3(c) 403.12(l) 403.3(e) 403.6, EPA Model Ordinance EPA Model Ordinance 403 App E 403.3(f) 403 App E 403.3(i) 403.3(j) 403.3(k) x A. Definitions x x x x x x x x x x x 118-202 118-201 " " " " " N/A 118-201 " " " " x x x Comments / Notes Inconsistent Absent Inconsistent National Pretreatment Standard, Pretreatment Standard or Standard (b),(c) New Source Pass Through Person Pollutant POTW Pretreatment Pretreatment Requirement Significant Industrial User 403.3(l) 403.3(m) 403.3(p) 403.3(q) 403.3(s) 403.3(t) 403.3(v) x x x x x x x x x " " " " " " " N/A 118-201 Significant Noncompliance 403.8(f)(2)(viii) x 118-212 Slug Load or Slug Discharge 403.8(f)(2)(vi) Interference Pass Through 403.5(a) 403.5(a) Fire/Explosion Hazard (60 C or 140 F 403.5(b)(1) flashpoint) x B - Prohibited Discharges 1 - General Prohibitions x x 2. - Specific Prohibitions 118-201 118-203 " x 118-203 x Inconsistent x Inconsistent x Inconsistent x Absent Inconsistent Non-Significant CIU x Adopted? Yes No 45-day reporting deadline Adopted? Yes No 2 pH/Corrosion Solid or Viscous/Obstruction Flow Rate/Concentration (BOD, etc.) Heat; exceeds 40 C (104F) Petroleum/Nonbiodegradable Cutting/Mineral Oils Toxic Gases/Vapor/Fumes Trucked/Hauled Waste Local Limits Development 403.5(b)(2) 403.5(b)(3) 403.5(b)(4) 403.5(b)(5) 403.5(b)(6) 403.5(b)(7) 403.5(b)(8) 403.5(c) & (d) Development of BMPs as local limits and Pretreatment Standards Require compliance with applicable Pretreatment Standards and Requirements by IUs Prohibition Against Dilution as Treatment Deny/Condition New or Increased Contributions Special Agreements Contracts Establishes owner and tenant are both responsible Permit Application Requirements Individual Permits required? General Permits allowed? 403.5(c)(4) 403.8(f)(1)(ii) 403.6(d) 403.8(f)(1)(i) x x x x x x x " " " " " N/A 118-203 x 118-203 x N/A x x 118-204 x 118-203 C. Permit Conditions x 118-207 x 118-203 x 118-206 x 118-208 x 118-207 Yes No x Absent Absent (only if authorized by state law) 3 Individual and General Control Mechanism (e.g., permit) to ensure compliance 403.8(f)(1)(iii) x 118-206 x Statement of Duration Statement of Non-transferability Effluent Limits General/Specific Prohibitions 403.8(f)(1)(B)(1) x 403.8(f)(1)(B)(2) x 403.8(f)(1)(B)(3) x x 118-208 " " IUDP form template, x pg. 3 Best Management Practices 403.8(f)(1)(B)(3) x 118-208 Self-Monitoring Requirements 403.8(f)(1)(B)(4) x " Reporting & Notification 403.8(f)(1)(B)(4) x " Requirements Recordkeeping Requirements 403.8(f)(1)(B)(4) x " Process for Seeking a Waiver for 403.8(f)(1)(B)(4) Pollutants Not Present or Expected to and 403.12(e)(2) x N/A be Present Statement of Applicable Civil and Criminal Penalties 403.8(f)(1)(B)(5) x 118-208 Requirement to Control Slug 403.8(f)(1)(B)(6) x " Discharges (if necessary) Immediate Notification of changes 403.8(f)(2)(vi) x affecting potential for a slug discharge 118-209 Continuation of Expired Permits x 118-208 Permit Modification x " Duty to Halt/Reduce x 118-213 Sampling Facilities x IUDP form template D. Require Development of Compliance Schedule and Reporting Requirements Develop compliance schedule for 403.8(f)(1)(iv) x installation of technology Reporting Requirements - 403.12 Correct "into the without" to "into the POTW without" Inconsistent; Add Toxic Gases/Vapor/Fumes specific prohibition N/A 4 Baseline monitoring report (i) - Identifying Information (ii) - Other Environmental Permits Held (iii) - Description of operations (iv) - Flow measurements - All wastestreams (v) - Measurement of pollutants (Streamlining updated): (vi) - Certification (vii) - Compliance schedule and progress reports 90-day compliance report for categorical Pretreatment Standards Periodic reports on continued compliance - From categorical users - From significant non-categorical users Notice of potential problems (including slug loads) to be reported immediately 24-hour notification of violations 30-day re-sampling requirement Requirement to conduct representative sampling Notification of changed discharge Notification of discharge of hazardous waste 403.12(b) 403.12(b)(1) 403.12(b)(2) x N/A x N/A x N/A 403.12(b)(3) 403.12(b)(4) x N/A x N/A 403.12(b)(5) x N/A 403.12(b)(6) x N/A 403.12(b)(7) and x N/A 403.12(c) 403.12(d) x 118-209 403.12(e) 403.12(h) 403.12(f) 403.12(g)(2) 403.12(g)(2) 403.12(g)(3) 403.12(j) 403.12(p) x x x 118-209 x " x " x " x " x N/A Other Reporting Requirements x Absent x Absent x Absent x Absent x Absent x Absent x Absent x Absent x Inconsistent x Absent x Absent x Absent 5 Reporting certification and authorized 403.6(a)(2)(ii) x signatory and 403.12(l) 118-207 Recordkeeping Requirement (3 years or longer) 403.12(o) x 118-209 x - Including documentation associated 403.12(o) with Best Management Practice x " x Submission of all monitoring data. 403.12(g)(6) x Annual certification by Non-significant 403.3(v)(2) categorical Industrial User x N/A x N/A Certification of pollutant not present 403.12(e)(2)(v) x N/A Reports for Non-Significant IUs x N/A Accidental Discharge Reporting x 118-205 Slug Discharge Control provisions x 118-204 Upset Provisions - categorical Pretreatment Standards only 403.16 x 118-217 x Bypasses and Notification 403.17 x 118-217 x E. Test Procedures [40 CFR Part 136 & 403.12(g)(3)] Analytical procedures (40 CFR Part 403.12(g)(5) x 136) Sample collection procedures 403.12(g)(3) and x (4) F. Inspection and Monitoring Procedures [403.8(f)(1)(v)] Inconsistent Inconsistent BMPs Adopted? Yes No Absent Adopted? Yes No Adopted? Yes No Inconsistent Inconsistent 6 Right of Entry 403.8(f)(1)(v) x Identify all IUs, flows and pollutants 403.8(f)(2)(i) x and (ii) Inspect and take samples 403.8(f)(1)(v) independent of IU and (f)(2)(v) and (f)(2)(vii) x 118-210 " " Use of digital photos during inspections and monitoring Right to require installation of monitoring equipment and facilities Right to inspect and copy records Enforcement Response Plan incorporated into legal authority Injunctive relief Civil penalties Criminal penalties Immediately halt actual/threatened discharged NOVs Consent Orders Show Cause Hearing Cease and Desist Order Administrative Orders Administrative Penalty Authority Falsification/Tampering Permit Termination Suspension of Sewer Service x N/A 403.8(f)(1)(iv) x 118-210 403.12(o)(2) x " G. Remedies for Non-compliance (Enforcement) [403.8(f)(1)(vi)] 403.8(f)(5) x 118-213-118-216 x 403.8(f)(1)(vi)(A) x x 403.8(f)(1)(vi)(A) x 403.8(f)(1)(vi)(B) x 118-214 " 118-216 118-212 x x x x x x x x x H. Public Participation 118-213 " " " " N/A 118-208 118-213 " Absent 7 Publish list of Industrial Users in Significant Noncompliance Access to data (confidentiality) 1. Government 2. Public Oil and Grease/Sand Interceptors Silver Mercury Other - Fats, Oils, and Grease (F.O.G.) Program Net/Gross adjustments 403.8(f)(2)(viii) x 118-212 403.8(f)(1)(vii) x 118-211 403.14(a)and (c) x " 403.14(b) x " I. BMPs and Sector Control Programs x N/A x N/A x N/A x N/A J. Optional Provisions 403.15 x N/A Convert concentration limits to mass 403.6(c)(5) limits x N/A Convert mass limits to concentration 403.6(c)(6) limits x N/A Reduce periodic compliance reporting 403.12(e)(3) (middle Tier CIU) x N/A Other special agreement or waivers (excluding wavier of National x Categorical Pretreatment Standards) Adopted? Yes No Adopted? Yes No Adopted? Yes No Adopted? Yes No Adopted? Yes No 8 Hauled Waste Reporting/Requirements x N/A Removal Credit 403.7 x N/A Outside Jurisdictions/IGAs x N/A 9 INDUSTRY NAME PERMIT EFFECTIVE DATE PARAMETER LOCAL LIMITS Copper Zinc Oil & grease BOD COD Total Solids pH Mercury Benzene Toluene Ethylbenzene Xylene Polynuclear Aromatic Hydrocarbons 10.1 lbs/d 0.02 lbs/d 50 ug/L 50 ug/L 50 ug/L 50 ug/L 50 ug/L Attachment 2.1: CONTROL MECHANISM WORKSHEET 12/22/2020 CATEGORICAL STANDARD MONTHLY AVERAGE DAILY MAXIMUM United Dairy, Inc. PERMIT EXPIRATION DATE PERMIT LIMIT MONTHLY AVERAGE DAILY MAXIMUM Monitor Monitor 200 mg/L Monitor Monitor Monitor 5-10 SU 12/21/2023 REQUIRED SAMPLE TYPE REQUIRED SAMPLE FREQUENCY Composite Composite Grab Composite Composite Composite Grab Quarterly Quarterly Monthly Monthly Monthly Monthly Monthly 1 INDUSTRY NAME DATE SAMPLE COLLECTED 11/01/21 - O&G*1 1/30/22 - MH1 3/27/22 - MH2 4/24/22 - MH2 11/1/2021 - MH1, MH26 1/20/21 - MH1, MH4 2/16/2021 - MH1 2/16/2021 - MH2, MH4 POLLUTANTS NOT SAMPLED O&G, metals, BOD,COD, TS2 Sampling Worksheet United Dairy, Inc. CONTROL AUTHORITY MONITORING VIOLATIONS? (Y/N/PARAMETER) DATE SAMPLE COLLECTED POLLUTANTS NOT SAMPLED Y 5/25/22 - MH1 Y - pH3 Y - O&G Y - O&G Y- O&G Y- pH Y - pH 6/20/22 - MH1 7/24/2022 - MH1 MH2 - 8/29/22 6/17/2021 - MH1, MH2, MH4 10/26/2021 - MH1 10/26/2021 - MH2 Sept, Oct, Nov, Dec.5 Y - O&G 11/21/2021 - MH2 VIOLATIONS? (Y/N/PARAMETER) O&G - Y O&G - Y O&G - Y O&G - Y4 Y- pH Y - O&G Y- pH Y- O&G 1 * the control authority sampled through PACE 2 No samples provided for the Control Authority sampling in 2022. Note on record indicate sampling by Control authority would occur on the 4th quarter of 2022 but didn't see this record. 3 No resample available post violati0on of pH limits at MH1 4 No resample provided after violation 5 No samples submitted for BOD, COD, TS, metals, or pH for the months of September through December of 2022 6 Sampled by CSB 2 INDUSTRY NAME 4/28/2021 - MH4 IS THIS A RESAMPLE? Y Y Y Y REPORT DUE DATE 5/24/22 6/25/22 7/20/22 8/24/2022 United Dairy, Inc. Y- pH 12/19/2021 - MH1 INDUSTRIAL USER SELF-MONITORING REPORT RECEIVED SAMPLE DATE(S) POLLUTANTS NOT SAMPLED 5/22/22 6/17/22 9/4/22 9/1/2022 Y - O&G VIOLATIONS? (Y/N/PARAMETER) Y - O&G Y - O&G 3 Enforcement Worksheet INDUSTRY NAME DATE OF VIOLATION TYPE OF VIOLATION TYPE OF ACTION AND DATE February 25, 2022 January 18, 2021 Failure to pretreat water, failure to report potential problems in discharged waters, failure to properly O&M treatment system, failure to halt discharge to maintain compliance with permit. Discharge of 978 gallons of raw milk into the POTW Notice of violation (NOV-1091-2022): included action items requiring a corrective action plan, installation of temporary pretreatment system, and pH chart recorder from which UDI will send CSB weekly records of pH levels, and disconnecting the untreated water from pallet and case washers to the pretreatment system; penalty of $31,000 by 4/1/22 Notice of violation (NOV-1092021): required action items by 2/22/2021 include sending training material along with roster of employees needing training for tankman/ gasket installation ERP REQUIRED RESPONSE NOV, penalties NOV IU RESPONSE DATE DATE COMPLIANCE ACHIEVED 3/15/2022 and again 3/31/2022: description of temporary pH pretreatment system, periodic pH monitoring sent to CSB, and penalties paid 3/31/2022 2/18/2021 2/18/2021 4 INDUSTRY NAME DATE OF VIOLATION TYPE OF VIOLATION February 25, 2022 Failure to send DMRs to CSB, or notify/resample after pH and oil&grease violations in DMR reports TYPE OF ACTION AND DATE Notice of violation (NOV 1092-2022), response to why DMRs weren't sent to CSB and why no notification was given of pH and oil&grease violations and paid penalty ($2,000) - on or before 4/1/2022 ERP REQUIRED RESPONSE NOV, penalty IU RESPONSE DATE DATE COMPLIANCE ACHIEVED 4/7/2022 ? 5 INDUSTRY NAME PERMIT EFFECTIVE DATE PARAMETER LOCAL LIMITS BOD N/A pH N/A TOTAL FLOW N/A CONDENSATION N/A AMMONIA N/A TDS N/A CHLORIDES N/A STORAGE TANK N/A LEVEL COD N/A TSS N/A ARSENIC N/A Attachment 2.2: CONTROL MECHANISM WORKSHEET 12/22/2020 CATEGORICAL STANDARD MONTHLY AVERAGE DAILY MAXIMUM N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 1 City of Charleston Sanitary Landfill PERMIT EXPIRATION DATE PERMIT LIMIT MONTHLY AVERAGE DAILY MAXIMUM 380 lbs/day 7-day 400 lbs/day N/A 6-10 N/A 100,000 gpd 6,000 gpd Total 4.17 gpm 275 lbs/day 7-day 300 lbs/day Monitor Only Monitor Only Monitor Only Monitor Only 12/21/2023 REQUIRED SAMPLE TYPE REQUIRED SAMPLE FREQUENCY 24-HR COMPOSITE GRAB METER 4/WEEK 1/WEEK CONTINUOUS METER CONTINUOUS 24-HR COMPOSITE 24-HR COMPOSITE 24-HR COMPOSITE 4/WEEK 1/WEEK 1/WEEK Monitor Only Monitor Only TANK GAUGE 1/DAY Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only 24-HR COMPOSITE 24-HR COMPOSITE 24-HR COMPOSITE 1/MONTH 1/MONTH 4/YEAR INDUSTRY NAME PERMIT EFFECTIVE DATE PARAMETER LOCAL LIMITS CADMIUM N/A CHROMIUM N/A COPPER N/A CYANIDE N/A LEAD N/A MERCURY N/A NICKEL N/A SILVER N/A ZINC N/A 12/22/2020 CATEGORICAL STANDARD MONTHLY AVERAGE DAILY MAXIMUM N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A City of Charleston Sanitary Landfill PERMIT EXPIRATION DATE PERMIT LIMIT MONTHLY AVERAGE DAILY MAXIMUM Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only Monitor Only 12/21/2023 REQUIRED SAMPLE TYPE REQUIRED SAMPLE FREQUENCY 24-HR COMPOSITE 24-HR COMPOSITE 24-HR COMPOSITE GRAB 24-HR COMPOSITE 24-HR COMPOSITE 24-HR COMPOSITE 24-HR COMPOSITE 24-HR COMPOSITE 4/YEAR 4/YEAR 4/YEAR 4/YEAR 4/YEAR 4/YEAR 4/YEAR 4/YEAR 4/YEAR 2 INDUSTRY NAME DATE SAMPLE COLLECTED 9/16/2021 POLLUTANTS NOT SAMPLED N/A IS THIS A RESAMPLE? N N N N Y N N N N N N REPORT DUE DATE 3/1/2021 4/1/2021 5/1/2021 6/1/2021 7/1/2021 8/1/2021 9/1/2021 10/1/2021 11/1/2021 12/1/2021 1/1/2022 Sampling Worksheet City of Charleston Sanitary Landfill CONTROL AUTHORITY MONITORING VIOLATIONS? (Y/N/PARAMETER) DATE SAMPLE COLLECTED POLLUTANTS NOT SAMPLED N N/A N/A INDUSTRIAL USER SELF-MONITORING REPORT RECEIVED SAMPLE DATE(S) POLLUTANTS NOT SAMPLED 2/11/2021 January 2021 N/A 3/12/2021 February 2021 N/A 4/14/2021 March 2021 N/A 5/12/2021 April 2021 N/A 6/7/2021 May 2021 N/A 7/19/2021 June 2021 N/A 8/16/2021 July 2021 N/A 9/10/2021 August 2021 N/A 10/28/2021 September 2021 N/A 11/29/2021 October 2021 N/A 1/12/2022 November 2021 N/A 3 VIOLATIONS? (Y/N/PARAMETER) N/A VIOLATIONS? (Y/N/PARAMETER) N N N Y (Limit Exceedances) N N N N N N Y (Late Submission, COVID-related) INDUSTRY NAME City of Charleston Sanitary Landfill N 2/1/2022 1/28/2022 December 2021 N/A N N 3/1/2022 2/24/2022 January 2022 N/A N N 4/1/2022 3/15/2022 February 2022 N/A N N 5/1/2022 4/8/2022 March 2022 N/A N N 6/1/2022 5/18/2022 April 2022 N/A N N 7/1/2022 6/27/2022 May 2022 N/A N N 8/1/2022 7/28/2022 June 2022 N/A N N 9/1/2022 8/18/2022 July 2022 N/A N N 10/1/2022 9/14/2022 August 2022 N/A N 4 INDUSTRY NAME DATE OF VIOLATION TYPE OF VIOLATION 4/8-14/2021 4/15-21/2021 Exceedances (2) of daily maximum limit for NH3-N. Exceedance (1) of daily maximum limit for NH3-N. Enforcement Worksheet TYPE OF ACTION AND DATE City of Charleston Sanitary Landfill ERP REQUIRED RESPONSE IU RESPONSE DATE No action. N/A N/A No action. N/A N/A DATE COMPLIANCE ACHIEVED Resampled. Resampled. 5 INDUSTRY NAME PERMIT EFFECTIVE DATE PARAMETER LOCAL LIMITS Zinc TSS BOD COD Attachment 2.3: CONTROL MECHANISM WORKSHEET Charleston Area Medical Center General Hospital 12/30/2020 PERMIT EXPIRATION DATE 12/29/2023 CATEGORICAL STANDARD MONTHLY AVERAGE DAILY MAXIMUM PERMIT LIMIT MONTHLY AVERAGE DAILY MAXIMUM REQUIRED SAMPLE TYPE REQUIRED SAMPLE FREQUENCY Monitor-only Composite Semi-annually Monitor-only Composite Semi-annually Monitor-only Composite Semi-annually Monitor-only Composite Semi-annually 1 INDUSTRY NAME DATE SAMPLE COLLECTED 12/7-8/2021 8/9-10/2022 8/15-16/2022 BOD Sampled* NOTHING FURTHER PROVIDED POLLUTANTS NOT SAMPLED N BOD* N/A IS THIS A RESAMPLE? N N N NOTHING FURTHER PROVIDED REPORT DUE DATE Sampling Worksheet Charleston Area Medical Center General Hospital CONTROL AUTHORITY MONITORING VIOLATIONS? (Y/N/PARAMETER) DATE SAMPLE COLLECTED POLLUTANTS NOT SAMPLED VIOLATIONS? (Y/N/PARAMETER) N N N INDUSTRIAL USER SELF-MONITORING REPORT RECEIVED SAMPLE DATE(S) 7/14/2021 6/23-24/2021 1/10/2022 12/20-21/2021 7/25/2022 6/28-29/2022 POLLUTANTS NOT SAMPLED BOD - VIOLATIONS? (Y/N/PARAMETER) N N N 2 INDUSTRY NAME DATE OF VIOLATION TYPE OF VIOLATION N/A N/A Enforcement Worksheet Charleston Area Medical Center General Hospital TYPE OF ACTION AND DATE ERP REQUIRED RESPONSE IU RESPONSE DATE DATE COMPLIANCE ACHIEVED 3 INDUSTRY NAME PERMIT EFFECTIVE DATE PARAMETER LOCAL LIMITS Zinc TSS BOD COD Cyanide Mercury pH Attachment 2.4: CONTROL MECHANISM WORKSHEET Charleston Area Medical Center Memorial Hospital 12/30/2020 PERMIT EXPIRATION DATE 12/29/2023 CATEGORICAL STANDARD MONTHLY AVERAGE DAILY MAXIMUM PERMIT LIMIT MONTHLY AVERAGE DAILY MAXIMUM REQUIRED SAMPLE TYPE REQUIRED SAMPLE FREQUENCY Monitor-only Composite Semi-annually Monitor-only Composite Semi-annually Monitor-only Composite Semi-annually Monitor-only Composite Semi-annually Monitor-only Grab Semi-annually Monitor-only Composite Semi-annually 5-10 SU Monitor-only Grab Weekly 1 INDUSTRY NAME DATE SAMPLE COLLECTED 12/14/21 9/7-9/8/2022 POLLUTANTS NOT SAMPLED Mercury, pH N Sampling Worksheet Charleston Area Medical Center Memorial Hospital CONTROL AUTHORITY MONITORING VIOLATIONS? (Y/N/PARAMETER) DATE SAMPLE COLLECTED POLLUTANTS NOT SAMPLED VIOLATIONS? (Y/N/PARAMETER) N N IS THIS A RESAMPLE? N N N NOTHING FURTHER PROVIDED REPORT DUE DATE 8/1/21 2/1/22 8/1/22 INDUSTRIAL USER SELF-MONITORING REPORT RECEIVED SAMPLE DATE(S) 7/22/2021 1/21-6/25/2021 1/24/2022 7/2-12/31/2021 7/22/2022 1/3-6/27/2022 POLLUTANTS NOT SAMPLED - VIOLATIONS? (Y/N/PARAMETER) N N N 2 INDUSTRY NAME DATE OF VIOLATION TYPE OF VIOLATION N/A N/A Enforcement Worksheet Charleston Area Medical Center Memorial Hospital TYPE OF ACTION AND DATE ERP REQUIRED RESPONSE IU RESPONSE DATE DATE COMPLIANCE ACHIEVED 3 Attachment 3: PERMIT FORM REVIEW - United Dairy, Inc. As part of the audit conducted of the pretreatment program of the Charleston Sanitation Board, a review of a sample permit was conducted. For this review, the permit issued to United Dairy, Inc., effective December 22, 2020, was used. In addition to the key elements of the permit that are evaluated during the file review, a review of the permit was conducted to evaluate consistency with the General Pretreatment Regulations (including the October 14, 2005 amendments) and local ordinances. Even where the permit is not inconsistent with EPA regulations or local ordinances, the provisions of the permit have been reviewed for suggested wording changes to strengthen or clarify the permits. Comments detailed below are intended to clarify the notations on the attached permit. Typographical errors identified during the review are noted on the attached copy of the reviewed permit. General: It is unclear whether this specific user is subject to any best management requirements (spill/slug control would often fall within the definition of best management practices) based on the narrative currently included in the permit. Based on the streamlining amendments to EPA's pretreatment regulations, if the user is subject to any best management practice requirements, to implement the pretreatment requirements and local limits, these BMP requirements must be included in the permit. In addition, where best management practices apply, the user must be required to provide documentation demonstrating compliance with the best management practices. Missing Provisions: While Section III(B.) of the permit application has information regarding the authorized Wastestream discharged from the wastewater treatment plant, the permit does not include language identifying the specific waste stream authorized for discharge. A short description of the authorized Wastestream discharged from this facility should be included in the permit going forward. The permit does not include notification of appeal rights. It is strongly recommended that CSB include language specifying the process to appeal a permit in the permit's narrative. The permit does not list the local limit pertaining to the United Dairy. Moreover, the effluent limits as they appear on the permit for United Dairy are not consistent with the local limits listed on CSB's SUO. The Industrial user permit should have effluent limits consistent with the local limits on the City's SUO, per 40 cfr 403.8(f)(1)(B)(3). If the CSB wishes for the Dairy to use the effluent limits as they currently appear on their permit, then CSB needs to make amendments to their SUO to include such effluent limits in the place of the local limits currently listed on the SUO or include language to allow for limit variances in their SUO. The permit did not include narrative clarifying the requirement for a slug control plan. If CSB has determined that a slug control plan is necessary for this Industrial User (IU), then CSB is required to include such a requirement in the IU permit, per 40 cfr 403.8(f)(1)(B)(6). If this is the case for United Dairy, please amend the permit language to include slug control requirements. There was no language concerning upset and bypass provisions on the permit. CSB must add language concerning regarding upset per 40 cfr 403.16 or bypass per 40 cfr 403.17. Currently the IU permit doesn't have language requiring the notification of hazardous wastes. Please add language requiring notification of hazardous wastes in the IU discharge consistent with 40 cfr 403.12(p) or incorporate it by reference, in part II of the permit. 1 of 5  The IU permit does not have language which gives CSB the right to enter all parts of the facility at reasonable times, or inspect for compliance, or take independent samples, or to view and copy records. CSB must include language authorizing the board the right to enter the Industrial user at will at reasonable times for the aforementioned reasons, per 40 cfr parts 403.8(f)(1)(iv-vii) and 403.12(o)(2). The permit language did not include a prohibition against dilution as treatment. CSB is required to add language to prohibit using dilution as treatment, per 40 cfr 403.6(d). The permit language did not include a requirement to conduct representative sampling, per 403.12(g)(3). CSB is required to update he permit to include such requirement for representative samples in its language. Language Needing Amendments: Please include the following language on page 4 for prohibition #8, to be consistent with 40 cfr 403.5(b)(7): "...may cause acute worker health and safety problems" While Part II subpart G of the industrial user permit includes requirements to report slug discharges, the narrative lacks consistency with regulatory language at 403.8(f)(2)(vi). Please amend the permit language at part II subpart G to be consistent with such regulatory language. Part II, subpart C of the IU permit does not include a requirement to maintain sample type information from monitoring activities, which is a required streamlining provision. Please added language describing the required sample collection procedures or sample types for monitoring activities, per 403.12(g)(3)&(4). The statement of non-transferability on Part III subpart G of the permit is missing the requirement to provide a copy of the control mechanism to new owner/operator before finalizing permit transfers, per 403.8(f)(1)(B)(2). Please amend this language to include such requirement. While Page 7 of the permit includes the title of "responsible corp. official" and its definition per CSB's SUP by reference, the permit does not include an adequate definition for "Authorized representative". CSB must add the definition for Authorized representative of the user, consistent with the regulatory language at 40 cfr 403.12(l), to the permit. Permit Review Checklist - United Dairy, Inc. Permit Provision Revision None Rec Req Is the permit signed by the Y appropriate POTW representative? Is the permit inappropriately signed Y by an IU representative? Are the permit pages numbered? Y Section 2 of 5 Permit Provision Does the permit identify the specific wastestreams authorized for discharge? Does the control mechanism include acceptable language for: legal authority cite? issuance, expiration, and effective date? notification of appeal rights? requirement to reapply before expiration? effluent limits including all local limits? BMP requirements? sampling location? sampling frequency? sample type? - correct use of grab/composite samples? slug control requirements? all prohibitions included? Revision None Rec Req N Section Section III(B) of permit application has this information, but not on permit. Y p.1, cover page Y p.1, cover page N Y p.1, cover page Effluent limits, p.2, part I.A. No local limits listed N on the permit. CSB SUO's local limits are inconsistent with the effluent limits in United Dairy, Inc.'s permit. Y Y Y p.2, part I.B. Y p.2, part I.B. Y p.2, part I.B. N N p. 4, toxic substances prohibition 3 of 5 Permit Provision upset & bypass consistent with ordinance and 40 CFR 403? industrial user reporting requirements: - self-monitoring reports? - BMP compliance reports? - notice of potential problems, incl. slugs? - resampling requirement? - use of 136 methods? - report more frequent monitoring? - notification of changed discharge? - notification of facility change affecting slug discharge potential? - record-keeping requirements: maintain for 3 years? sample date? sample time? sample location? sample type? name of sampler(s)? sample preservation? analyses dates? name(s) of analyst? Revision None Rec Req N Section Y N Y Y Y Y Y Part II subpart (G.) of permit includes requirement to report N slug discharges, but lacks consistency with regulatory language at 403.8(f)(2)(vi) Y Y Y Y Y Y Y Y Y 4 of 5 Permit Provision analytical methods? analytical results? BMP compliance information? - signatory requirement? - certification statement? - hazardous waste notification? right of entry? penalty provisions? non-transferability? revocation of permit? dilution prohibition? representative sampling? correct definition of SNC? correct definition of authorized representative? other conditions (list)? - Revision None Rec Req Y Y N Y Y N N Y N Y N N Y Y Section Language regarding use of BMP to implement program limits is unclear. Unsure if BMPs used in place of local limits 5 of 5 Attachment 4.1: INDUSTRIAL USER VISIT REPORT Date: 01/26/2023 Time: 9:21 AM Industry name: United Dairy, Inc. Address: 508 Roane St, Charleston, WV 25302 Contact name(s) Title Phone James Ward Maintenance Manager N/A Charlie Edgar Plant Manager N/A Scotty Wallmack Quality Control N/A Persons conducting visit: Name Title Affiliation Aron Possler Life Scientist U.S. EPA Region 3 Natalie Sanchez-Gonzalez Life Scientist U.S. EPA Region 3 Margaret Green Life Scientist U.S. EPA Headquarters Ryan Shuart Life Scientist U.S. EPA Region 3 James Kline Physical Scientist U.S. EPA Region 3 Netar Wadhwa Pretreatment Coordinator WVDEP Tim Haapala Operations Manager CSB Erik Roberts Environmental Compliance Manager CSB Linda Hammonds Environmental Compliance Technician CSB Purpose for visit: Observed inspection by the Charleston Sanitary Board. Brief facility description: Food processing, milk. Comments/Findings: Refer to Section X: Findings, Requirements, and Recommendations of the POTW Pretreatment Program Audit Report. Page 1 of 1 Attachment 4.2: INDUSTRIAL USER VISIT REPORT Date: 01/26/2023 Time: 1:33 PM Industry name: City of Charleston Sanitary Landfill Address: 741 S Park Rd, Charleston, WV 25304 Contact name(s) Title Phone Craig Arnold District Manager N/A Persons conducting visit: Name Title Affiliation Aron Possler Life Scientist U.S. EPA Region 3 Natalie Sanchez-Gonzalez Life Scientist U.S. EPA Region 3 Margaret Green Life Scientist U.S. EPA Headquarters Ryan Shuart Life Scientist U.S. EPA Region 3 James Kline Physical Scientist U.S. EPA Region 3 Netar Wadhwa Pretreatment Coordinator WVDEP Tim Haapala Operations Manager CSB Erik Roberts Environmental Compliance Manager CSB Linda Hammonds Environmental Compliance Technician CSB Purpose for visit: Observed inspection by the Charleston Sanitary Board. Brief facility description: Waste management, landfill. Comments/Findings: Refer to Section X: Findings, Requirements, and Recommendations of the POTW Pretreatment Program Audit Report. Page 1 of 1 Attachment 5: AUDIT ACTION ITEMS -- Charleston Sanitary Board (CSB) Audit Date -- January 25-26, 2023 Findings Several required and recommended revisions to CSB's sewer use ordinance. Refer to Section X, Subsection A and Attachment 1 of the audit report. Local limits in the SUO are not approved by WVDEP. CSB applies limits within industrial user discharge permits with no justification or approved local limits. Pollutants that have caused or contributed to historic P/I do not maintain local limits. CSB allocates a local limits MAIL value of "0 lbs/day" or "monitor only" for several SIUs. CSB does not document allocation of local limits MAIL. Status Legal Authority Application of Standards Completion Date (Estimate) 1 of 4 Findings The term "medical wastes" is inconsistent with the prohibition of sewering "hazardous waste pharmaceuticals". Several required and recommended revisions to the industrial user discharge permit template. Refer to Section X, Subsection C and Attachment 3 of the audit report. United Dairy: The industrial user discharge permit does not maintain good housekeeping practices. Several SIU sampling locations are not fully accessible. Several outfalls of SIUs are not sampled, with no justification provided. Status Control Mechanism Compliance Monitoring Completion Date (Estimate) 2 of 4 Findings Inspection reports do not include the name of the inspector(s) or the time of the inspection. Sampling report do not include the name of the sampler. Chain of custody forms do not include the name or title of those involved. United Dairy: CSB conducts sampling on a regular schedule. United Dairy: CSB does not completely record meetings not considered as part of a "full inspection". United Dairy: The Audit Team noted historical and significant variations in BOD5. CSB does not maintain an ERP. United Dairy: CSB accepts prohibited discharge of "milk and milk products". Potential SIUs/CIUs are not surveyed in accordance with the definitions of SIUs/CIUs. Status Enforcement Data Management & Public Participation 3 of 4 Completion Date (Estimate) Findings CSB accepts electronic DMRs from SIUs. CSB does not maintain a collection of one-time compliance reports for dental dischargers. CSB does not detail its Industrial Waste Survey inventory. Status Completion Date (Estimate) 4 of 4