Document MJzzr66X98wMgZBnQwYLkXjk

REPORT OF THE PRETREATMENT COMPLIANCE INSPECTION The City of McPherson P.O. Box 1008 McPherson, Kansas 67460 NPDES permit No.: KS0036196 BY U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 7 ENFORCEMENT AND COMPLIANCE ASSURANCE DIVISION (ECAD) WATER BRANCH/DRINKING WATER & INSPECTIONS SECTION (WB/DWIS) ON July 11 and 12, 2024 At the request of the Water Branch (WB), Enforcement and Compliance Assurance Division (ECAD), a Pretreatment Compliance Inspection of the McPherson Approved Industrial Pretreatment Program (IPP) was conducted on July 11 and 12, 2024. To direct the inspection, a checklist was used that evaluates all important elements of the Pretreatment Program. A copy of the checklist is attached to this report (Attachment 1). The inspection consisted of a discussion with the IPP personnel and file review of the IPP's program records, and visit to Femco, Inc. In addition, I conducted brief file review of the city's Biosolids Management Program (Sludge). Mr. Steve Caspers, with the Kansas Department of Health and Environment (KDHE), and Mr. Justin Kensinger, with the Environmental Protection Agency Region 7, were present for this inspection. This narrative report presents the findings of the inspection. Participants City of McPherson Wastewater Treatment Facility (WWTF) x Michael D. Wagner, Superintendent mikew@mcpcity.com Femco, Inc. x Greg Cunningham, QC/Safety Compliance Officer KDHE-Bureau of Water-Industrial Program Section x Steve Caspers, Pretreatment Specialist. Steve.Caspers@ks.gov U.S. Environmental Protection Agency (EPA), Region 7 x Naji J. Ahmad, Environmental Engineer, ECAD/WB/DWIS x Justin Kensinger, Pretreatment Coordinator, WD/PWD Ahmad.Naji@epa.gov Kensinger.Justin.R@epa.gov Facility Description The city of McPherson owns and operates one activated sludge Wastewater Treatment Facility (WWTF) serving a community of 13,865 people and at least seven industries. The WWTF is located at 1400 Treatment Plant Road. The plant is permitted under the Kansas National Pollutant Discharge Elimination System (NPDES) permit number KS0036196 that will expire on May 31, 2025. The WWTF includes a Sequencing Batch Reactor (SBR) technology as a modification to the activated sludge process for the treatment of wastewater. According to the NPDES permit, the WWTF has a design treatment capacity of 2.0 million gallons per day (mgd), with a maximum weekly peak capacity up to 3.0 mgd. According to Mr. Michael Wagner, the plant's 2023 actual average daily flow was 1.3 mgd. The WWTF receives discharges from seven Significant Industrial Users (SIUs) that make up 20% of its actual (average dry weather) influent of 1.3 mgd. The treated wastewater (effluent) is discharged from the SBR to a reaeration basin for the addition of oxygen. It exits the reaeration basin and passes through the ultraviolet (UV) disinfection unit before being discharged to Dry Turkey Creek via Outfall 001. A portion of this effluent is diverted prior to the outfall for use within the treatment facility and for irrigation of the Dry Turkey Creek Golf Course. The remainder of the effluent is pumped to the CHS, Inc. Refinery to use within their system, which allows CHS to conserve ground water resources. Mr. Wagner indicated that 60% of the effluent is sent to the CHS Refinery. Industrial Pretreatment Program Overview The city of McPherson Industrial Pretreatment Program (IPP) was originally approved on October 24, 1983. The city's local limits were approved on October 31, 2000, and the most recent attempts (with the help of EPA and KDHE) to evaluate the local limits were conducted in 2011 (Attachment 2) and 2021 (Attachment 3) based on the Maximum Allowable Headworks Loading for the WWTF and Maximum Allowable Industrial Loading. Table 1, McPherson' WWTF 2011 Local Limits Pollutant MAIL Pollutant MAIL (lbs/day) (lbs/day) Arsenic 0.427 Mercury 0.005 Cadmium 0.068 Molybdenum NA Cyanide 0.195 Nickel 2.559 Chromium 0.342 Selenium NA Copper 4.533 Silver 0.237 Lead 0.727 Zinc 20.56 The EPA and KDHE, during the PCI, agreed that the EPA would re-calculate the local limits for the city this year, if the city provided the necessary data. The authority to enforce the IPP is listed under Chapter 86, Article IV of the McPherson code of ordinance number 238, also known as the sewer use ordinance (SUO), that was approved on July 17, 1991. The ordinance gives the city the authority to implement and enforce the IPP, such as issuing permits for a duration of five years or less; requires the submittal of permit renewal applications prior to the expiration of the permit; and the right to inspect, sample, enforce, and collect fines not less than $100.00, nor more than $1,000.00 for each offense under section 86278. This section doesn't conform to 40 CFR 403.8(f)(1)(vi)(A) which requires at least the amount of $1,000 a day for each violation by industrial users of Pretreatment Standards and Requirements. In 2001, the city made changes to temperature and pH limitations within the SUO which was approved by the EPA on October 31, 2001. In addition, the city adopted the oil and grease ordinance on February 5, 2018. The city has not yet incorporated the required amendments to the General Pretreatment Regulations [40 CFR 403.8, 40 CFR 403.13] published in the Federal Register on October 14, 2005, known as the Streamlining Rule. I informed Mr. Wagner that this is a preliminary finding for not meeting the General Pretreatment Regulations. I also reminded him that the city was notified of this requirement during the last EPA Pretreatment Audit in 2020. Mr. Wagner indicated that he is in the process of evaluating the city's SUO for compliance with the Streamlining regulations (Attachment 4). Mr. Wagner has been the responsible person for coordinating the McPherson IPP, the operation of the WWTF, the Sludge Management Program, and the Fat, Oil and Grease Program for almost 30 years. The McPherson IPP doesn't have a set frequency to conduct an industrial waste survey. However, the IPP continues to conduct informal industrial surveys and it is part of McPherson inter-departmental communication where IPP personnel would know if new industries were planning on connecting to the sanitary sewers. Records indicated that the last formal IWS was completed in 2016. The regulated industrial community, however, has remained consistent over the past few years. Currently there are seven regulated Significant Industrial Users (SIU) all of which, except Pfizer (Hospira), are located within the McPherson city limits and all of which are subject to pretreatment categorical standards. Six industries are subject to the Metal Finishing Categorical Standard 40 CFR Part 433, and Pfizer is subject to the Pharmaceutical Manufacturing Categorical Standard 40 CFR 439. Approximately 20% of the WWTF's influent flow comes from industrial sources and majority of the industrial flow is from Pfizer alone. The city does not accept hauled waste. The McPherson IP identified and sent the one-time compliance report (OTCR) to all dental offices in 2017 under the Dental Amalgam Rule or 40 CFR Part 441. The city used the Kansas Dental Association and the Kansas Dental Board lists of dental offices provided by Mr. Steve Caspers. The IPP continues to send the OTCR to any new dental offices that begin operation in the city and the city's website also has the needed information about the Amalgam rule: https://www.mcpcity.com/641/Dental-Office-Category. Industrial User Permits All industries have current permits, and the IPP continues to issue permits with a three-year duration. Overall, the permits appeared to contain the necessary elements that should be included in an enforceable permit as required by 40 CFR 403.8 (f) (1) (iii). Records indicate that industries submitted complete and adequate permit renewal applications. Steve Caspers pointed out to Mr. Wanger that pH is not listed in the pollutants monitoring frequency table in the Femco Permit (Attachment 5). Inspections Records indicated that all SIUs were inspected in the past 12 months. Inspections are usually done in the month of December by Mr. Wagner. Mr. Wagner continues to use a two-page checklist in place of the six-page Region 7 Industrial User Inspection Checklist. During the inspection, Mr. Wagner mentioned that KDHE provided the city with a new and more comprehensive checklist that he is planning on using in the future. Overall, inspection checklists were properly completed and included notes of issues noted during previous inspections. Determining the need for a slug control plan (SCP) is done by the PC during the inspection. However, I pointed out to Mr. Wagner during my review of the checklist, that the checklist does not include facility process description (Attachment 6). Compliance Monitoring, Self-Monitoring, and Reporting Section 86-254 of the SUO gives the IPP the authority to sample its industries and to identify sampling frequencies of regulated pollutants, monitoring of Pollutants of Concern, and sampling locations. The IPP samples all industries at least annually for all regulated pollutants. However, during the review of the Pfizer compliance monitoring data, we noticed that the city did not monitor for all regulated pollutants. The city failed to monitor for n-Amyl Acetate, Ethyl Acetate, Isopropyl Acetate, and Methylene Chloride for at least the past five years. This is mainly because the IPP's Industrial Pretreatment Program Self-Monitoring (For Pharmaceutical Industries) Form did not list those four pollutants as it is indicated in the permit. The Pfizer permit requires a semi-annual monitoring of BOD, TSS, oil & grease, acetone, temperature, pH, and annual monitoring of n-Amyl Acetate, Ethyl Acetate, Isopropyl Acetate, and Methylene Chloride. I informed Mr. Wagner that this is a preliminary finding of the General Pretreatment Regulations. Mr. Wagner revised the monitoring form to include the required additional four pollutants (Attachment 7). I also pointed out that Pfizer did monitor for all regulated pollutants as required. Self-monitoring requirement is the same for all industries except for Pfizer. All industries are required to sample once every six calendar months, but Pfizer is required to conduct annual monitoring of n-Amyl Acetate, Ethyl Acetate, Isopropyl Acetate, and Methylene Chloride. The city is capable of sampling with short notices and using analytical methods that conform to 40 CFR Part 136. Industries are required to submit semi-annual self-monitoring reports no later than 30 days after the end of the reporting period. Semi-annual reports appeared to be submitted accordingly and included the certification statements. Industries that are subject to the electroplating, metal finishing, and electrical and electronic components categories submitted total toxic organics (TTO) certification indicating that they are implementing a Solvent Management Plan (SMP)/Toxic Organics Management Plan (TOMP) in lieu of TTO monitoring. Mr. Wagner indicated all six industries subject to such categorical standards chose to develop and implement an SMP and submit the TTO certification statements. Records indicated that Femco submitted the TOMP plan with the certification statement. The last plan revision was on June 19, 2024 (Attachment 8). It was also noted that Femco TOMP did not include Acetone in the list of pollutants. Enforcement The current Enforcement Response Plan (ERP) was originally approved on January 15, 1991, after the EPA model ERP. The ERP has not been revised since the original approval. Mr. Wagner indicated that the IPP is currently revising the ERP (Attachment 9) while the city is also working on revising the SUO to include the Streamlining Rule changes. The current ERP is being revised to change titles of personnel mentioned in the ERP due to personnel changes. 40 CFR 403.8(f)(5)(ii) states that the ERP shall, at a minimum: "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. The time periods are for the POTW to initiate and take enforcement and that not included in the ERP." Section 86-278 - Violations, Penalties indicates that: "(a) Civil penalties. Any user that is found to have violated an order of the governing body or who failed to comply with any provision of this article, and the orders, rules, regulations and permits issued under this article, shall be fined not less than $100.00, nor more than $1,000.00 for each offense. Each day on which a violation shall occur or continue shall be deemed a separate and distinct offense. In addition to the penalties provided in this subsection, the city may recover reasonable attorneys' fees, court costs, court reporters' fees and other expenses of litigation by appropriate suit at law against the person found to have violated this article or the orders, rules, regulations and permits issued under this article. (b) Criminal penalties. Any user that is found to have willfully or negligently failed to comply with any provision of this article, and the orders, rules, regulations and permits issued under this article, shall be fined not less than $100.00, nor more than $1,000.00 for each offense or by imprisonment for not more than six months, or both such fine and imprisonment. Each day on which a violation shall occur or continue shall be deemed a separate and distinct offense. In addition to the penalties provided in this subsection, the city may recover reasonable attorneys' fees, court costs, court reporters' fees and other expenses of litigation by appropriate suit at law against the person found to have violated this article or the orders, rules, regulations and permits issued under this article. (c) Liability. Any person violating any of the provisions of this article shall become liable to the city for any expense, loss or damage occasioned the city by reason of such violation, including such fines, penalties and other costs which may be assessed to the city for violation of sewage treatment plant effluent requirements, where such violation was created by a user of the sewer works who, in turn, is in violation of city, state or federal regulations. Based on this language, the ERP appears to be inconsistent with the required thresholds established in in the pretreatment regulations. Records indicated that all industries were in full compliance during the 2022 and 2023 calendar years. Records also indicated that the last notice of violations were issued on February 23, 2022, to Specialties Technologies for exceeding the daily maximum and monthly average limits for lead (Pb) during the second half of 2021. It appeared that Mr. Wagner followed the guidelines of the ERP. Site visit to Femco Inc. Steve Caspers, Justin Kensinger, Mike Wagner and I, traveled to Femco Inc., located at 1132 West 1st St in McPherson, to observe the IPP Coordinator conduct an industrial user inspection and to investigate if any of the 40 processes under 433.10 are used on site. Femco is considered a categorical industrial user (CIU) subject to the Metal Finishing Standard 40 CFR, Part 433.17 because it discharges process wastes from a three-stage phosphating operation since the phosphating operation is used to prepare steel for paint (a conversion coating operation) which is one of the six core processes under the Metal Finishing Standard. Femco mainly manufactures roll bars, weathering enclosures, and various specialty parts for agricultural and recreational equipment. Raw materials include steel tubing, steel sheets and paint. Outfall 001 is located at a clean-out in the service lateral north of the receiving area. Outfall 001 waste stream is sampled semi-annually for all parameters listed in Part 433.17. Total toxic organics (TTO) are not sampled because the facility chose to submit TTO certification that they are implementing an SMP in lieu of TTO monitoring. The industry submitted their revised TOMP on June 19, 2024. Mr. Wagner was the lead inspector. He started the inspection with an opening conference and completed most of the checklist. Then we toured the production areas, chemical storage, and phosphate cleaning system. There were no processes from the 40 sub-processes under 433.10 used on site. The inspection was thorough and adequately evaluated the industry's compliance with IU permit. Data Management Overall, industrial files have all the necessary documentation as recommended by the Agency checklist. Each file consisted of permit and permit renewal applications, inspection reports, monitoring reports, and correspondence between the IPP Inspector and the industry. Records are well kept by Mr. Wagner at the WWTF and maintained for more than three years and are available for public review. Records are also kept electronically. Sludge Quality (Attachment 10) One function of the Pretreatment Program is to protect the city's sludge from metals contamination. As part of this audit, the most recent calendar year sludge monitoring reports were reviewed to determine the Pretreatment Program's effectiveness. In 2023 the WWTF generated 152 dry metric tons of Class B sludge, and in 2022 the WWTF generated 113 dry metric tons of Class B sludge. Sludge handling operation at the WWTF consists of a four-cell aerobic digester, a centrifuge thickener, and an off-site sludge storage facility. The digester receives excess sludge from the SBRs. After digestion, the sludge is pumped to the centrifuge thickener where it is further dewatered to a dryness of approximately 20% to 22%. Dewatered sludge is transported to the off-site storage facility until its land applied. The city applies biosolids in February and/or November to City owned agricultural land. The city has a total of 223 acres for land application and only utilizes 70 acres annually. Land application is done by a contractor. Below is the table that compares the city's peak observed metal levels against the statutory ceiling and the City's average level against the exceptional quality (EQ) sludge level as specified by the 40 CFR Part 503 Sludge regulations. Because the City sampled its sludge quarterly, the monthly average is the maximum value observed. As shown in the table, the City's sludge is below the ceiling level for all metals. Table 3, 2023 McPherson WWTF Sludge Quality (mg/kg) Pollutant Arsenic, As Chromium Cadmium, Cd Copper, Cu Lead, Pb Mercury, Hg Molybdenum , Mo Nickel, Ni Selenium, Se Zinc, Zn 503 Ceiling 75 3000 85 4300 840 57 75 420 100 7500 503 EQ 41 1200 39 1500 300 17 ---420 36 2800 Max 8 1363 2 1578 32 0.35 21 31 32 1299 Mo. Avg. 8 1363 2 1578 32 0.35 21 31 32 1299 Max/Ceiling 10.67% 45.43% 2.35% 36.70% 3.81% 0.61% 28.00% 7.38% 32.00% 17.32% Avg./EQ 19.51% 113.58% 5.13% 105.20% 10.67% 2.06% 7.38% 88.89% 46.39% Conclusion & Recommendations The city has not yet incorporated the required amendments to the General Pretreatment Regulations [40 CFR 403.7, 403.8, 403.12, and 403.13] published in the Federal Register on October 14, 2005, known as the Streamlining Rule. The city was notified of this requirement during the last Pretreatment Audit in 2020. Mr. Wagner indicated that he is in the process of evaluating the city's SUO for compliance with the Streamlining regulations. The city's local limits were approved on October 31, 2000, and the most recent attempts (with the help of EPA and KDHE) to evaluate the local limits were in 2011 and 2021, based on the Maximum Allowable Headworks Loading for the WWTF and the Maximum Allowable Industrial Loading. Mr. Wagner has been overseeing and managing the McPherson IPP for almost 30 years. The city should cross-train additional qualified staff members on implementing the IPP. The city failed to monitor Pfizer for n-Amyl Acetate, Ethyl Acetate, Isopropyl Acetate, and Methylene Chloride for at least the past five years. Inspection reports should include facility process description. It is also recommended that the IPP use the EPA six-page industrial users inspection checklist. It is recommended that the city ensure that the civil penalties amount, listed under Chapter 86Articl IV-Section 86-278 of the city ordinance, meets the requirement of 40 CFR 403.8(f)(1)(vi)(A) which requires that civil penalties should be at least the amount of $1,000 a day for each violation by industrial users of Pretreatment Standards and Requirements. The ERP defines the type of enforcement action to be taken by the IPP but does not establish time periods (timeline) for initiating enforcement as required by the 40 CFR 403.8(f)(5)(ii). The city should consider including language such as "the PC will review industrial user reports within five days of receipt and for minor errors may issue the form letter notification within an additional seven days. Formal notices of violation will generally be issued within 30 days of receipt of the report." NAJI AHMAD Digitally signed by NAJI AHMAD Date: 2024.08.20 14:59:06 -05'00' Naji J. Ahmad Environmental Engineer, WB/DWIS NICOLE MORAN Digitally signed by NICOLE MORAN Date: 2024.08.21 08:56:55 -05'00' Nicole Moran Section Supervisor, WB/DWIS Attachments 1. PCI Checklist 2. 2011 Local Limits Evaluation 3. 2021 Local Limits Evaluation 4. Draft SUO 5. Permits 6. Inspections 7. SMR 8. Femco TOMP 9. ERP 10. Sludge Checklist & Data PCI Date(s): July 11 and 12, 224 FY 2024 Approved Pretreatment Program POTW: Address: CITY OF MCPHERSON P.O. BOX 1008 MCPHERSON, KS 7460 Contact: Title: Phone: Cell: Mike Wagner Superintendent 620-245-2540 620-245-7744 e-mail mikew@mcpcity.com Date of last PCI/Audit: December 14, 2022 NPDES Permit No.: KS0036196 State Permit No.: M-LA11-OO01 Expiration Date: 4/30/2025 Participants POTW: Mike Wagner, Superintendent Inspectors: Naji J. Ahmad, EPA Region 7 Justin Kensinger, EPA PC Steve Caspers, Bureau of Water , KDHE Period covered by this PCI/Audit: 2022 and 2023 POTW Information Total for ALL Treatment Plants (MGD) Design Daily Ave. 2.0 Actual Daily Ave. 1.3 Design Peak: 3.0 weekly % Industrial Flow: 20 Number of Plants: 1 % Combined Sewers: 0 Type of Treatment at Principal Plant: Activated Sludge- SBR Sludge Disposal Method: Quantity (dry/tons/Y): Receiving Stream: Land application Dry Turkey Creek 60% of the WWTP effluent is sent to CHS refinery and the rest is used to irrigate the golf course. PART I: PROGRAM BACKGROUND INFORMATION I.A. Approved Modifications to the Original Program 1. Date of last NPDES permit modification: 09/01/2002 Date of original Program approval: Date NPDES Permit originally modified to require implementation [PTIM]: 10/24/1983 7/8/1987 2. Approved Pretreatment Program modifications: REQUIRED MODIFICATIONS APPROVAL DATE OTHER APPROVED MODIFICATIONS APPROVAL DATE PIRT SUO Revisions 7/17/1991 Ordinance limit pH & Temp 10/31/2001 List of SIUs [403.8(f)(6)] 2018 Oil and Grease Ordinance 2/5/2018 Enforcement Response Plan 1/15/1991 DSS SUO Revisions 7/17/1991 LOCAL LIMITS 10/31/2000 3. Is the POTW presently working on any program modifications? Local limits, revising the SUO to incorporate the Streamlining rule, and the 1991 ERP. 4. Does the POTW have any program modifications currently being reviewed by the Approval Authority? NO. However, KDHE is helping with the SUO. I.B. Approved Program Contents 5. Authority to enforce Pretreatment Standards contained in: Sewer Use Ordinance (SUO) number 2368, Chapter 86 Article IV 6. Date enacted or adopted: 01/20/1995 7. Approved Control Mechanism: PERMITS 8. What is the frequency required by the approved program/modifications for: Activity POTW sampling of: POTW inspection of: SIU self-monitoring: SIU reporting: Non-categorical SIUs 1 1 2 2 Categorical SIUs* 1 1 2 2 2 9. What types of enforcement options are available through the approved program: Y Notice of Violation (NOV) Y Administrative Order (AO) Y Show Cause Hearing Y Establishment of Compliance Schedules Y Revocation of Permit Y Injunctive Relief NO Fines; in at least $1000/day/violation [40 CFR 403.8(f)(1)(vi)(A)] Y Criminal Penalties Y Termination of Service 10. COMMENTS: Section 86-278. - Violations; Penalties (a) Civil penalties. Any user that is found to have violated an order of the governing body or who failed to comply with any provision of this article, and the orders, rules, regulations and permits issued under this article, shall be fined not less than $100.00, nor more than $1,000.00 for each offense. Each day on which a violation shall occur or continue shall be deemed a separate and distinct offense. In addition to the penalties provided in this subsection, the city may recover reasonable attorneys' fees, court costs, court reporters' fees and other expenses of litigation by appropriate suit at law against the person found to have violated this article or the orders, rules, regulations and permits issued under this article. (b) Criminal penalties. Any user that is found to have willfully or negligently failed to comply with any provision of this article, and the orders, rules, regulations and permits issued under this article, shall be fined not less than $100.00, nor more than $1,000.00 for each offense or by imprisonment for not more than six months, or both such fine and imprisonment. Each day on which a violation shall occur or continue shall be deemed a separate and distinct offense. In addition to the penalties provided in this subsection, the city may recover reasonable attorneys' fees, court costs, court reporters' fees and other expenses of litigation by appropriate suit at law against the person found to have violated this article or the orders, rules, regulations and permits issued under this article. (c) Liability. Any person violating any of the provisions of this article shall become liable to the city for any expense, loss or damage occasioned the city by reason of such violation, including such fines, penalties and other costs which may be assessed to the city for violation of sewage treatment plant effluent requirements, where such violation was created by a user of the sewer works who, in turn, is in violation of city, state or federal regulations. 3 PART II: INTERVIEW QUESTIONS II.A. Legal Authority and Jurisdiction 11. Have any Pretreatment modifications been made to the Sewer Use Ordinance since the last PCI/Audit that have not been approved by the Approval Authority. NO 12. List by name and location any SIUs that discharge to the POTW from outlying jurisdictions. Pfizer (Hospira) Indicate which of the above are not covered by a contract/agreement requiring them to abide by the POTWs legal authority. NONE 13. Does the POTW have the authority to seek fines in at least $1000/day? [403.8(f)(1)(vi)] NO. 14. If the POTW has not yet developed an Enforcement Response Plan when does the POTW feel it will complete this requirement? 1995 15. COMMENTS: working with KDHE on the SU, LL, and ERP. II. B. Control Mechanism 16.General Information: Type: PERMITS Issued to Noncategorical SIUs? [DSS: 403.8(f)(2)(i)] Duration: 3 YEARS* YES * Section 86-306 (a)Permits shall be issued for a specific time period, not to exceed five years. 17.Do all SIUs have current (unexpired) control mechanisms? {NOCM} YES 18.List by name those that do not and indicate which ones have not had a current control mechanism for 180 days or more. {RNC/SNC}NONE II.C. Hauled Wastes 19. Does the POTW accept hauled waste? (If "no," go to question 25) NO because of the SBR system. a. if so describe (include approx. no. of loads per month): b. How does the POTW ensure that it does not accept hazardous waste? 20. Does the POTW have a control mechanism for regulating waste haulers, and if so describe. NONE 21. Does the POTW have a designated discharge point (or points) for waste haulers? [DSS: 403.5(b)(8)] Describe: NONE 22. Are all applicable Categorical standards and Local Limits applied to IUs whose wastes are hauled to NA 4 23. Describe the method used to apply local limits to hauled waste. NA 24. COMMENTS: II.D. Industrial User Characterization 25. How often does the POTW update its Industrial Waste Survey (IWS) to identify new SIUs or changes to wastewater discharges? Every few years. City started developing a list of industries to be surveyed. a. When was the last formal update: 2016 26. What is the POTW's current industrial base? Current Industrial User Type Last Reported* 7 Categorical SIUs 7 {CIUS} 0 Non-Categorical SIUs 7 Total all SIUs 7 {SIUS} II.E. Local Limits 27. Does the POTW have numerical limits for metals in its NPDES permit? If so list the metals and the limits (or attach list). NO 28. Have there been any numerical NPDES permit violations in the last 12 months? NO a. Were any of the numerical NPDES violations, identified above, a result of interference or pass through? NO 1. Was the interference traceable to an industrial user? 2. Was action taken that led to elimination within 90 days of the interference or pass through? {SNC} 3. Was the responsible industry placed on an enforceable compliance schedule within 90 days of discovery? {SNC} If not, why? 29. How many times per year does the POTW regularly sample its PRINCIPAL plant for the following? Parameter Metals Toxic Organics Biomonitoring TCLP Influent 0 0 Effluent 1/5 years 1 1 Sludge 4 NA NA 5 30. List below the numerical value for the local limits derived by technical analysis. If a technical analysis was performed but the limit not adopted enter DNA in the block. (Values assumed to be mg/l unless otherwise noted). {EVLL} {ADLL} 2000 POLLUTANT DAILY MAX POLLUTANT DAILY MAX ARSENIC CADMIUM CHROMIUM COPPER CYANIDE 0.382lbs 0.053 lbs 4.386 lbs 2.411 lbs 0.195 lbs LEAD MERCURY NICKEL SILVER ZINC 0.55lbs 0.002 lbs 1.970 lbs 0.207 lbs 17.987 lbs 31. Are the POTW's BOD and TSS limits technically derived (ie. based on plant capacity)? YES 32. Are BOD and TSS violations treated as violations of technically based local limits? YES 33. If there is more than one treatment plant, were the local limits established specifically for each plant? NA 34. Has the POTW made any changes to its Local Limits which have not been approved, and if so provide details? [403.18] NO 35. Has the POTW granted any Net/Gross allowances under 403.15? NO 36. COMMENTS: The city has been working with the EPA to recalculate its local limits since 2011. II.F. Standards and Requirements for Industrial Users 37. Does the POTW compare local limits against federal Categorical standards and apply the most stringent standards to Categorical IUs? [403.4] YES 38. Has the POTW notified its IUs of possible RCRA obligations? [40 CFR 403.8(f)(2)] YES 39. Does the POTW allow Categorical users to use Solvent Management Plans/certification or surrogate test procedures to meet TTO requirements? YES II.G. POTW Compliance Monitoring and Inspections 40. What is the current frequency for: Activity POTW sampling of: POTW inspection of: SIU self-monitoring: SIU reporting: * For Categorical pollutants Non-categorical SIUs 1 1 2 2 Categorical SIUs* 1 1 2 2 6 41. List exceptions: NONE. 42. List those SIUs that were not sampled by the POTW within the last 12 months. [DSS: 403.8(f)(2)(v)] NONE. 43. List those SIUs that were not inspected within the last 12 months. [DSS: 403.8(f)(2)(v)] NONE. 44. How many industries were neither sampled nor inspected within the last 12 months. [DSS: 403.8(f)(2)(v)] {NOIN}{RNC/SNC} NONE. 45. Does the POTW sample its SIUs for all regulated pollutants at least once annually? [403.8(f)(2)(v)] NO. The IPP failed to sample for n-Amyl Acetate, Isopropyl Acetate, and Methylene Chloride as regulated pollutants in Hospira (Pfizer Inc.) industrial permit. The industry is subject to 40 CFR Part 439, Subpart D - Pharmaceutical Manufacturing. The industry does sample for all regulated pollutants. But the IPP doesn't. 46. Sample/Analysis Procedures: Chain-of-Custody always used? YES Sampling method, metals: GRAB Ability to sample on short notice? YES Sampling method, CN: GRAB In-house analysis of toxic pollutants: NONE Sampling method, O&G: GRAB Do in-house analytical methods conform to 40 CFR part 136? YES 47. How does the POTW document its industrial user inspections? A 2-page CHECKLIST 48. Does the POTW evaluate all SIUs at least every two years to determine the need for a slug discharge/spill control plan? [DSS: 403.8(f)(2)(v)] YES. a. Describe the method used by the POTW to evaluate the need for a slug control plan. During annual inspections. II.H. IU Self Monitoring and Reporting 49. Are all Categorical IUs required to self-monitor for all pollutants regulated by the respective Categorical standard at least twice per year? [403.12(e)] YES 50. Were any Baseline Monitoring Reports or 90 day Compliance Reports due within the past 12 months? If so, from whom? Were the reports submitted? NO 51. Are IUs required to report spills, slug discharges, etc. to the POTW? [403.12(f)] YES 52. Are IUs required to report violations within 24 hours of knowledge of the violation? [403.12(g)(2)] YES 53. Are IUs required to resample and submit results within 30 days following a violation as per 403.12(g)(2)? YES 7 II.I. Data Management 54. Are files/records computerized? YES 55. Are all records maintained for at least 3 years? [403.12(o)] YES 56. Are program records available to the public as required by 40 CFR 403.14(b)? YES 57. Does the POTW have provisions to address confidential business information? [403.14(a)] YES 58. How is compliance status calculated? Describe the procedure used in determining Significant Noncompliance (eg. are mo. avg. violations considered as well as daily max?). CITY follows EPA's definition. II.J. Program Resources 59. What percent of the Pretreatment Coordinator's time is spent on pretreatment? 10% 60. What computer programs does the POTW use for: Wordprocessing: Ms WORDS Spreadsheet: Excel Database: Operator 10.0 61. Does the POTW believe its annual budget adequate for implementation? YES. a. If not, is the level of money available for pretreatment less than that in the approved program or approved modification? II.K. Special Questions 62. Are there any issues that the POTW would like to discuss? 8 PART III: FILE AND RECORDS REVIEW Following is a table containing the POTW's Significant Industrial User inventory regulated by its Pretreatment Program. Please verify that all information in the table is correct and current. For those industries no longer regulated draw a line through the entry. Add all new industries and provide the information sought by the table. Below is a guide to the information sought by the table and suggested abbreviations. INDUSTRY: Provide the name of each industrial user regulated under the pretreatment program. CAT STND: Provide the categorical standard code number. For example, industries subject to the Metal Finishing regulation should be designated "433." For noncategorical industries indicate "NA" in this column. REG PROCESS: Indicate what process the industry performs to qualify for inclusion in the pretreatment program. For example, if an industry is subject to Metal Finishing regulations because it performs zinc and chromium plating indicate with "ZnCrPL" or a similar abbreviation. TMT: If the facility treats its wastestream(s) indicate "Y." If no treatment is provided indicate "N." TYPE: Indicate the type of pretreatment system (if applicable) the industry has. Suggested abbreviations: "precip" for precipitation/clarification; "precp/flt" for precipitation followed by filtration; "DAF" for dissolved air flotation; etc. REG FLOW: Provide the industry's average daily flow for its regulated processes in gallons per day. The abbreviation "K" stands for 1000. TOT FLOW: Provide the average daily total plant flow in gallons per day. CWF: Indicate if the industry uses the Combined Wastestream Formula to determine compliance with categorical standards. "Y" = yes, "N" = no. COMPLIANCE STATUS FOR THE 6 MO PERIOD ENDING: For the six month periods listed, indicate if the industry's compliance status. Use the following abbreviations: CIn compliance with all standards: no violations. IInfrequent noncompliance with discharge standards: the facility had some violations but not severe enough to be considered in significant noncompliance. SNC,SIn significant noncompliance with discharge standards. SNC,RIn significant noncompliance with reporting requirements: the industry failed by greater than 30 days to submit reports as required. SNC,MIn significant noncompliance with self monitoring requirements: the industry did not properly report its compliance status on its self monitoring report. SNC,C Failure to meet a compliance schedule milestone by 90 days. LAST INSPECTION: Date of the last inspection performed by th 9 SECTION VII: SIGNIFICANT INDUSTRIAL USERS Industry Name Femco Inc. Hospira Ind. Chrome Specialties 1 Ind. Chrome Specialties 2 Precision Industries 1 Precision Industries 2 Specialty Technology . Cat. Stnd 433 439 433 433 433 433 433 Reg. Process FePhos Pharm Hrd CrPl Hrd CrPl Hrd CrPl Hrd CrPl Hrd CrPl T M T Type C Compliance Status for Six Month Period W Ending: Last Reg. Total F Inspection Flow Flow JUN 22 DEC 22 JUN 23 DEC 23 N 1.8K 2K N C C N 138K 191K N C C Y Evap/PorPots 0 0.6K N I-R C Y Evap 0 0.5K N I-R C Y Evap/PorPots 0 23K N C C Y Evap/PorPots 0 0 NC C N 0.06K 0.45K N C C C C 12/18/2023 C C 12/20/2023 C C 12/21/2023 C C 12/21/2023 C C 12/19/2023 C C 12/19/2023 C C 12/11/2023 11 III.B. Significant Industrial User Compliance Evaluation 63. From the above list of industries, how many are in Significant Noncompliance (SNC) with either discharge standards or reporting requirements based on the most recent six-month reporting period? {PSNC} NONE 64. List by name, those industries currently on a compliance schedule. Complete the table below. NONE Industry Name Date Schedule Issued Compliance Deadline How Administered* eg. Administrative Order, Permit, etc. 65. List those industries last published in the newspaper for noncompliance and provide the date (or attach a copy of the public notice). NONE 66. If an industry has been deleted from the list of Significant Industrial Users list by name below and provide the reason. NONE 67. For those industries in SNC within the last 12 months complete the following table for all written enforcement actions. IU Name Violation Date of Date of Action Enforcement ERP required POTW Action action knowledge NONE 68. Provide the total number of NOVs, Administrative actions, Judicial referrals, and criminal prosecutions that occurred in the last twelve months. {FENF} {JUDI} NONE 69. Were all actions taken by the POTW within 30 days of knowledge of a violation? {RNC/SNC} NA 70. Did all industries in SNC either return to compliance within 90 days, receive escalated enforcement action by the POTW within 90 days, or become placed on an enforceable compliance schedule within 90 days (of knowledge by the POTW) of the violation? {RNC/SNC} NA 12 III.C. Control Mechanism Evaluation 71. Do the POTWs control mechanisms: Permittee: REQUIRED [DSS: 403.8(f)(1)(iii)] SUGGESTED PROVISIONS Specify duration (no > 5 yrs.): Y Cite the POTW's legal authority: Y Contain the correct discharge limits: Y Identify TTO alternatives, if applicable: Y Specify sample type for IU self monitoring: Y Require notification within 24 hrs of a violation: Y Adequately identify sampling location: Y Require resample/report in 30 days of violation: Y Specify sampling frequency: Y Specify right of entry: Y State applicability of civil or criminal penalties: Y Reserve right to revoke permit: Y Stipulate reporting frequency: Y Specify immediate slug load notification: Y Properly require records retention: Y Require submission of all sampling results: Y Specify limited transferability: Y Result of this review from the last PCI/audit: III.D. Industrial Inspection Evaluation 72. Do the Industrial Inspection reports contain? Name of Company contact: Y Evaluation of IU's monitoring procedures: Y Date of inspection: Y Verification of wastewater flow rates: Y Time of inspection: Y Determination of applicability of the CWF: NA Description of manufacturing process: N Description of the chemical storage area: Y Description of treatment process, if any: Y Identification of potential spill conditions: Y Evaluation of IU's monitoring methods: Y Correct Determination for the need for Slug Control Plan Y Verification of production rates that would affect production based standard: NA Inspection report should include Description of manufacturing process: 13 III.E. Slug Discharge Control Procedures 73. If the POTW has required the submittal of a Slug Control Plan does it contain: [DSS: 403.8(f)(2)(v)] ______ A description of discharge practices including non-routine batch discharges ______ A description of stored chemicals ______ Procedures for immediate notification of slug discharges with written follow-up notification ______ Procedures necessary to prevent adverse effects at the POTW's treatment plant: ______ inspection and maintenance of storage areas ______ handling and transfer of materials ______ loading and unloading operations ______ control of plant site runoff ______ worker training ______ building of containment structures ______ measures for the control of toxic organics ______ measures for emergency response 74. COMMENTS III.F. Industrial User File Review Checklists Following are worksheets to aid in the assessment of the nature of the oversight activities and compliance status of the POTW's Significant Industrial Users. When reviewing SIU files priority should be placed on Categorical industries that either have a history of violations or that appear to be in compliance but have not installed that prescribed BAT technology to consistently meet discharge limits. While only three pages are provided the reviewer is encouraged to copy and add additional review pages for larger POTWs 14 Industry Name: Hospira CIU 439.2(a) Principal Pollutants: BOD, TSS, pH, o&g, temp, Acetone, nAmyl Acetate, Isopropyl Acetate, and Methylene Chlorid No. of Employees: 1,744 Products: Formulation and packaging of injectable pharmaceuticals. Involved in chemical research or synthesis. A. Does the file system for the industrial user contain: ___X__ Permit application __x___ Current Permit ___x__ Correct limits in Permit ___x__ Correspondence/meeting notes/phone log ___x__ Most recent inspection report __x___ Evaluation for need for Slug control __x___ Compliance status determination YES POTW sampling results _YES___ Self-monitoring reports NA Enforcement documentation __YES_ Solvent Management Plan ___NA Correct application of the CWF ___YES__Slug Control Plan 1/28/2020 B. Did the industry discharge any slug loads or spills to the POTW in the past 12 months? NO [403.12(f)] _____ Immediate notification by the IU _____ POTW response _____ Follow-up written notification _____ Effect on the plant C. In the last complete calendar year how many times did the POTW: Sample the IU __1____ Inspect the IU ___1___ D. Were all regulated pollutants analyzed by the POTW at least once in the most recent calendar year? NO Never sampled Acetone, n-Amyl Acetate, Isopropyl Acetate, and Methylene Chloride. E. If the industry is subject to Categorical Standards did its self-monitoring reports contain analysis for all regulated pollutants at least once during every six month period during the last full calendar year? YES F. Frequency in the IU's control mechanism for: Self-monitoring __1-2____ Reporting ___2___ G. Did the industry comply with the sampling and reporting frequency requirements of its Control Mechanism? H. Did the POTW identify all IU violations from: IU Self-monitoring ___0___ POTW Compliance monitoring ___0___ I. Was the IU's compliance status (i.e. SNC, Infrequent noncompliance, Consistent compliance) determined properly? YES J. Complete the following table for all violations in the last 12 months. (If this information has already been provided in Question 85, please indicate). Date of Date of ERP Date of POTW POTW Required POTW Violation Violation Knowledge Response Response Response NA Comments: facility has SWPPP, SPCC, Emergency Response Plan, Hazardous Waste Management Plan, Slug Discharge Plan. 15 Industry Name: FEMCO CIU 433.17 Principal Pollutants: 433.17 POC Products: roll bars, weathering enclosures and various speciality parts for agricultural and recreational equipment No. of Employees: 45 A. Does the file system for the industrial user contain: YES Permit application YES__ Current Permit YES Correct limits in Permit YES_ Correspondence/meeting notes/phone log YES Most recent inspection report YES__ Evaluation for need for Slug control YES Compliance status determination YES POTW sampling results __YES__ Self-monitoring reports __NA___ Enforcement documentation __YES_Solvent Management Plan ___NA__ Correct application of the CWF ___NA__ Slug Control Plan B. Did the industry discharge any slug loads or spills to the POTW in the past 12 months? NO [403.12(f)] _____ Immediate notification by the IU _____ POTW response _____ Follow-up written notification _____ Effect on the plant C. In the last complete calendar year how many times did the POTW: Sample the IU __1____ Inspect the IU ___1___ D. Were all regulated pollutants analyzed by the POTW at least once in the most recent calendar year? YES E. If the industry is subject to Categorical Standards did its self-monitoring reports contain analysis for all regulated pollutants at least once during every six month period during the last full calendar year? YES F. Frequency in the IU's control mechanism for: Self-monitoring __2____ Reporting ___2___ G. Did the industry comply with the sampling and reporting frequency requirements of its Control Mechanism? H. Did the POTW identify all IU violations from: IU Self-monitoring ___0___ POTW Compliance monitoring ___0___ I. Was the IU's compliance status (i.e. SNC, Infrequent noncompliance, Consistent compliance) determined properly? YES J. Complete the following table for all violations in the last 12 months. (If this information has already been provided in Question 85, please indicate). Date of Date of ERP Date of POTW POTW Required POTW Violation Violation Knowledge Response Response Response NA Comments: Facility needs to include pH into the permit monitoring table. TOMP is missing Acetone from list of pollutants. 16 17