Document ZJRjzGyExRaEZGd6dxqNxwbRV

REPORT OF THE PRETREATMENT COMPLIANCE AUDIT Johnson County Wastewater 11811 South Sunset Drive, Suite 1700 Olathe, Kansas 66061-7061 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM KS0088269 January 29-31, 2025 BY UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 7 WATER DIVISION PERMITS AND LOANS BRANCH Contents INTRODUCTION ...................................................................................................................................... 2 PARTICIPANTS ....................................................................................................................................... 2 PROGRAM OVERVIEW .......................................................................................................................... 2 LEGAL AUTHORITY............................................................................................................................... 3 LOCAL LIMITS ......................................................................................................................................... 4 SIGNIFICANT INDUSTRIAL USERS .................................................................................................... 4 INDUSTRIAL WASTE SURVEY............................................................................................................. 4 INDUSTRIAL USER PERMITS ............................................................................................................... 4 SLUG CONTROL PLANS........................................................................................................................ 5 INDUSTRIAL INSPECTIONS ................................................................................................................. 5 COMPLIANCE MONITORING, SELF-MONITORING, and REPORTING...................................... 5 NET/GROSS ALLOWANCES ................................................................................................................. 5 ENFORCEMENT....................................................................................................................................... 6 OVERSIGHT INSPECTIONS .................................................................................................................. 6 HAULED WASTE ..................................................................................................................................... 7 SLUDGE MANAGEMENT ....................................................................................................................... 8 RECORDS MANAGEMENT.................................................................................................................. 10 CONCLUSION, EXPECTATIONS and RECOMMENDATIONS..................................................... 10 ATTACHMENTS .................................................................................................................................... 11 INTRODUCTION A Pretreatment Compliance Audit (PCA) was conducted of the Johnson County, Kansas, approved pretreatment program on January 29-31, 2025. To direct the PCA, a checklist was used that evaluates all important elements of the pretreatment program. A copy of the checklist is included with this report (Attachment 1). In addition, an evaluation of the Johnson County Wastewater (JCW) Biosolids Management Program (Sludge) was conducted to determine the Pretreatment Program's effectiveness in protecting the Wastewater Treatment Plants (WWTP). The PCA took place in this order: 1. Opening conference 2. Complete Audit Checklist 3. File Review 4. Control Authority Inspection 5. Approval Authority Inspection 6. Closing Conference This narrative report presents the PCA findings. Documentation collected during the audit will be submitted to and retained in the EPA's facility files. PARTICIPANTS Johnson County Wastewater David Becker, Pretreatment Coordinator Stephen Briggs, Industrial Pretreatment Specialist Dotty Harrison, Industrial Pretreatment Specialist Kansas Department of Health and Environment Steve Caspers, Pretreatment Specialist U.S. Environmental Protection Agency, Region 7 Justin Kensinger, Pretreatment Coordinator Naji Ahmed, Environmental Engineer PROGRAM OVERVIEW Johnson County, Kansas Wastewater (JCW) owns and operates six wastewater treatment plants. According to program staff, the WWTPs have a total design daily average flow of 79.4 million gallons per day, actual daily average flow of 55.4 MGD, and a design peak flow of 277.5 MGD. JCW currently regulates 21 significant industrial users. Four of the seven WWTPs receive industrial discharges from the 22 SIUs: 2 Middle Basin Mill Creek 1. Central 1. Biomune Biomedia, Company Incorporated 2. Deffenbaugh 2. Lenexa, Industries, WWTP, LLC Incorporated 3. SAFC 3. Disposable Biosciences, Instruments, Incorporated Company 4. **Simmons 4. Flowers Gun Repair Baking Co. of and Sales Lenexa, LLC 5. **Cintas 5. Kocher + Corporation Beck USA LP 6. Sparhawk Laboratories Incorporated 7. Tapco Products Company ** City of Olathe SIU New Century 1. Sauer Brands, Incorporated 2. International Flavors and Fragrances, Incorporated 3. Heartland Precision Fasteners, Incorporated 4. Flora Food Sourcing US, Incorporated Tomahawk Creek 1. Argenta US Manufacturing, LLC 2. Hennessy Research Associates, LLC 3. Inficon EDC, Incorporated 4. Ivy Animal Health Incorporated 5. TED Manufacturing Corporation 6. Universal Engraving, Incorporated LEGAL AUTHORITY JCW sewer use ordinance Articles 4, was originally approved by KDHE and the EPA on December 11, 1992. The SUO was updated in 2002 and approved on January 17, 2003. The ordinance is currently undergoing another revision. An ordinance evaluation was performed by the EPA and KDHE on February 25, 2021, and comments were provided to JCW. JCW pretreatment staff have completed the ordinance and are now waiting on JCW legal to finalize the rest of it. The ordinance gives JCW the authority to implement and enforce its pretreatment program, such as issuing permits for a duration of five years or less; requires the submittal of permit renewal applications a minimum of 90 days prior to the expiration date; and the right to inspect, sample, enforce, and to conduct enforcement activities including the collection of fines or penalties. During the PCA, I discussed with JCW staff the penalty structure included in the JCW SUO to determine if it complied with the general pretreatment regulation penalty structure established in 40 CFR 403.8(f)(1)(vi) that reads, "Obtain remedies for noncompliance by any Industrial User with any Pretreatment Standard and Requirement. All POTW's shall be able to seek injunctive relief for noncompliance by Industrial Users with Pretreatment Standards and Requirements. All POTWs shall also have authority to seek or assess civil or criminal penalties in at least the amount of $1,000 a day for each violation by Industrial Users of Pretreatment Standards and Requirements." I pointed out JCW staff that the current JCW ordinance does not comply the 40 CFR 403.8(f)(1)(vi). 3 LOCAL LIMITS The EPA and KDHE assisted JCW in the development of its current local limit calculations for each WWTP. The EPA approved the local limits for 12 metals, total suspended solids, ammonia, and biochemical oxygen demand on April 7, 2017. JCW submitted a local limits re-evaluation for the Tomahawk WWTP on February 13, 2025, and concluded that local limits will not be needed for the plant at this time. JCW is currently working on revaluating local limits for the other WWTPs. SIGNIFICANT INDUSTRIAL USERS There are currently 21 industrial users discharging to the county's WWTPs. This includes 13 categorical industrial users subject to categorical pretreatment standards. Of the 13 categorical industrial users, seven are subject to the Pharmaceutical Manufacturing Categorical Standard 40 Code of Federal Regulation Part 439, five are subject to the Metal Finishing Categorical Standard 40 CFR Part 433, and one is subject to the Electrical and Electronic Components Categorical Standard 40 CFR Part 469. Gill Studios, Incorporated's permit was terminated due to no reasonable potential for adversely affecting the POTW's operation or violating pretreatment standards. Excelligence Learning Corp. has changed its name to ELC Distribution Center, LLC. TriRx Shawnee, LLC was purchased and is now called Argenta US Manufacturing, LLC. Upfield Sourcing US has changed its name to Flora Food Sourcing US, Inc. IRCA New Century's permit was cancelled due to the facility shutting down. The city of Olathe and the JCW entered into an inter-jurisdictional agreement to ensure the pretreatment requirements are adequately enforced for two SIUs that are in the city of Olathe, but discharge into the JCW collection system. The two SIUs are Cintas Corporation and Simmons Gun, and both are regulated by the city of Olathe. INDUSTRIAL WASTE SURVEY JCW is performing a continuous review of the industrial/commercial customers in Johnson County to identify potential SIUs. This includes a monthly review of all industrial/commercial customers using over 25,000 gallons per day of potable water, reviewing emails from local Chambers of Commerce welcoming new businesses to the area, and researching the EPA's Enforcement and Compliance History Online website for hazardous waste generators and toxic release inventory reports. In addition, JCW requires sanitary sewer connection permits to be obtained by property owners for new commercial buildings in the service area. Also, for building expansions or tenant finish of existing building spaces, JCW requires the property owner and/or tenant to complete an application and submit construction plans for review by JCW. When a new potential significant industrial user is identified, JCW will send out an industrial waste form to characterize the wastestream and process to determine if a permit is necessary. INDUSTRIAL USER PERMITS Permits are issued with a five-year duration or less and contain the required elements in accordance with 40 CFR 403.8(f)(1)(iii) that should be included in a well written and enforceable permit. Permits include industrial process descriptions, provisions on accidental discharge, sampling and analysis procedures, self-monitoring and reporting frequencies. Local limits have not been incorporated into the CIU permits as it appears the categorical limits are more stringent. Local limits are included for NCSIUs. 4 SLUG/ACCIDENTAL SPILL CONTROL PLANS The need for an SIU to have a slug/accidental spill control plan is determined during routine annual inspections of the facility. If it is deemed that there is reasonable potential for the SIU to cause interference, pass through, or in any way disrupt operations at the POTW, then a slug/accidental spill control plan will be required. Careful examination and identification of the chemicals used and stored onsite, containment practices, location of floor drains, potential for spills are critical when assessing the need for a slug control plan. INDUSTRIAL INSPECTIONS All industries have been inspected during the last calendar year by JCW staff. Inspections are performed at least annually using a checklist that is similar to the EPA R7 Industrial User Inspection Checklist and include a narrative conclusion of the visit. Inspection reports appeared to be adequate, thorough, and well documented. Inspections consist of completing the checklist, records review, evaluation of the industry's need for a slug control plan, evaluation of the spill control plan (SCP) when applicable, and a facility walkthrough. Sampling may or may not be performed during the inspection but is performed by the JCW at least annually. COMPLIANCE MONITORING, SELF-MONITORING, and REPORTING Based on the industrial load, nature of the waste stream, pollutants concentration, and compliance history, self-monitoring frequencies vary from semiannually, monthly, weekly, and daily. Self-monitoring criteria is described in detail in the SIU permits. Reporting requirements also vary from one industry to another based on monitoring frequency, nature of discharge, etc. Reporting frequencies can vary from semiannually to monthly. The general pretreatment regulations allow industries that are subject to 40 CFR Part 433 to develop and implement a toxic organic management plan (TOMP) or solvent management plan in lieu of routine monitoring and allow certain CIUs to demonstrate compliance with total toxic organic requirements by certifying that the facility is adhering to the plan. Periodic monitoring reports are signed by the industry's responsible official and include the correct certification statement. Semi-annual reports required by the metal finishing categorical standard are signed by the industry's responsible official and include the correct Total Toxic Organics (TTO) certification statement. NET/GROSS ALLOWANCES Biomune Company, Hennessy Research Associates, LLC, and Argenta US Manufacturing are categorical pharmaceutical manufacturers limited to a maximum monthly average of 0.03 mg/L for chloroform. The public water supply (WaterOne) for these companies routinely generates chloroform concentrations within the drinking water system in excess of 0.03 mg/L. These three pharmaceutical companies do not use or generate chloroform in their process. The historical high levels of chloroform in the public water supply have caused them to exceed their pretreatment permit limits for chloroform. Therefore, these companies have been granted a net/gross calculation credit adjustment for chloroform at their facilities by JCW. The net/gross credit was jointly approved by KDHE and EPA. 5 ENFORCEMENT The JCW Enforcement Response Plan (ERP) was originally approved by the EPA and KDHE on January 15, 1991, and was revised June 2012. The ERP includes a series of procedures to deal with noncompliance and steps to escalate or elevate enforcement. These start with a phone/email notification, resampling, a compliance meeting, issuing a notice of violation and possible compliance schedule, and an increase in severity of enforcement actions which may include administrative, civil and/or criminal monetary penalties. During the file review, it appeared that most enforcement activities, such as telephone logs and written communications were taken in accordance with the guidelines of the ERP and were included in the individual industry files. When violations occur, JCW will call or email a notification to the industrial user. Records indicate that there were three industrial users in significant non-compliance during 2024. These three industries will be published in a newspaper of general circulation sometime in February 2025. There were 10 instances of infrequent non-compliance reported for 2024, these were for late reporting and permit limit exceedances. In calendar year 2024, a total of 62 notices of violations were issued. The top two industries representing 44 of the 62 of the notices of violations were Lenexa WWTP (27 NOVs) and Tapco Products (17 NOVs). Lenexa WWTP was placed on a compliance schedule which was completed on October 15, 2024. However, Lenexa WWTP still has infrequent non-compliance for biological oxygen demand (BOD) in the second half of the 2024 reporting period. Tapco Products was placed on a compliance schedule with a scheduled compliance date of August 12, 2025. Tapco remains in infrequent noncompliance for pH for the second half of the 2024 reporting period. Three SIUs were in significant non-compliance for calendar year 2024 including Flowers Baking Company of Lenexa, LLC, International Flavors and Fragrances, Inc., and Lenexa WWTP. No fines were collected from any of the SIUs who received an NOV or that were in Significant Noncompliance (SNC). OVERSIGHT INSPECTIONS Tapco Products Company An industrial user inspection was performed by JCW during the PCA at Tapco Products Company to evaluate the effectiveness, reliability, and completeness of the JCW inspection procedures and the administration of their approved pretreatment program. Tapco Products Company is an industrial laundry facility and is regulated as a significant industrial user. The facilities wastewater pretreatment system is designed as a constant flow treatment system with 2 pH probes. One pH probe is used as a controller to automatically add in chemicals to adjust the pH and is located directly into the treatment tank. The other probe is used for compliance and is located at the outfall. The pH controller probe is calibrated monthly, and the compliance pH probe is calibrated weekly. This SIU was selected for an oversight inspection because of recent non-compliance. EPA does this to try and understand and determine the reason for non-compliance and provide any possible solutions and suggestions to help the industry become compliant. Stephen Briggs led the inspection. He utilized their industrial pretreatment inspection report form and thoroughly covered all aspects of an industrial user inspection. 6 The first part of the inspection included questions to complete the inspection report form and complete the file review. Mr. Briggs then conducted visual observations of the facility led by Brad Pepin (President of Tapco). Mr. Pepin showed us the treatment system and explained how the system operates. The treatment system seemed to be operating properly at the time of the inspection. However, a main reason why Tapco has had recent non-compliance was due to the short duration of visual and audio alarms that sounds for the drum when there is a pH spike. It was confirmed during the inspection that the alarm system is not suitable for the working environment as it is not effective in warning workers that there is a problem with their treatment system. Mr. Pepin discussed the industry's efforts to adhere to the compliance schedule and figure out a solution to their continued pH limitation exceedances. The final date of their compliance schedule is May 29, 2025. Flowers Baking Company of Lenexa An industrial user inspection was conducted by EPA during the PCA to demonstrate to JCW staff how EPA conducts industrial user inspections. Flowers Baking Company was selected for an inspection because of the recent SNC for reporting and infrequent non-compliance with permit limit violations for oil and grease and pH. Flowers baking Company is an industrial bakery that produces many different types of bread products and is regulated as a significant industrial user. The first part of the inspection included questions and information gathering for the industrial user checklist and conducting a file review of facility documentation. We then conducted visual observations of the facility, led by Tim Kay (environmental safety and sustainability manager). The facility's treatment system utilizes pH neutralization and microfiltration to treat their industrial wastestream. Their microfiltration process is unique in that it utilizes ceramic filters made in Germany that must be replaced every 4 to 5 years. The treatment system utilizes two different holding tanks, one tank is batch discharged and the other one is hauled off. At the time of the inspection the treatment system was operating properly, and the system was in compliance with its permit limits. Mr. Kay explained that the reason for the SNC for reporting, was due to a problem with their contracted lab (Pace Laboratories). He explained that the reason for the exceedances for oil and grease was due to improper cleaning practices and mentioned they retrained staff to ensure they were cleaning properly. He also clarified that the reason why they were having problems with pH was because they needed to update the probe on their treatment system. HAULED WASTE JCW accepts domestic septic hauled waste at any of their treatment plants. Fats, oil and grease are accepted at the Middle Basin WWTP. Both septic and FOG waste haulers are required to apply for and obtain an annual license from the Johnson County Health and Environment Department. JCW personnel will randomly sample hauled waste for flashpoint and pH as a check for hazardous constituents. JCW also accepts special waste on a case-by-case bases if it was generated from within the county service area. Special waste can be accepted at any of the WWTPs, but they do not accept hauled waste from industries that are subject to categorical pretreatment standards. 7 SLUDGE MANAGEMENT (Attachment 2) As mentioned above, JCW owns and operates six (6) WWTPs: 1. Tomahawk Creek NPDES No. KS0055484) 2. Douglas L. Smith Middle Basin (NPDES No. KS0119601) 3. Mill Creek Regional Treatment Plant (NPDES No. KS0088269) 4. Nelson Complex (NPDES No. KS0055492) 5. Blue River Main (NPDES No. KS0092738) 6. New Century Air Center (NPDES No. KS0119296) The County generates Class B sludge from all six WWTPs. Most of the sludge is land applied and some is hauled off to the landfill. The County entered in an agreement with a third-party contractor to haul/transport and manage land application (Attachment 2). In 2024, generated sludge from the New Century and the Blue River WWTPs was trucked to the Nelson Complex WWTP. Sludge generated at the Nelson WWTP, combined with the trucked sludge, was sent to the landfill. In 2024, 4,272 dry metric tons (dmt) of combined sludge was sent to the landfill. No annual reports from those three facilities were required in 2024. Sludge generated from the Tomahawk Creek, the Douglas L. Smith Middel Basin, and the Mill Creek WWTPs was all land applied in 2023 and 2024. Below are the tables that compare the JCW produced sludge's (at the Tomahawk Creek, the Douglas L. Smith Middel Basin, and the Mill Creek WWTPs) peak observed metals level against the statutory ceiling and the average level against the exceptional quality (EQ) sludge level specified by the 40 CFR Part 503 Sludge regulations. Mill Creek WWTP, sewage sludge from the lagoon cells is usually removed and land applied during the last quarter of each year. The volume removed usually triggers the bimonthly (once per 60 days) sampling frequency required by 40 CFR 503.16. While the correct number of samples was taken (six times/per year) by JCW. It was taken during the period while they were land applying sludge. Under 40 CFR 503.16, JCW should have sampled their sludge once per 60 days (bimonthly period) as stated in Table 1 of 503.16. However, JCW needs to meet the minimum sample numbers required by the regulation. The timeframe does not need to meet the suggestion of every 60-days, but to be representative samples of the actual disposal period, instead of an old sample taken some time before the disposal event happens. This practice ensures that sampling is conducted of the biosolids being disposed and samples are collected at the time of the disposal event in accordance with 40 CFR 503.16. In 2024, sludge from the lagoon cells at the Mill Creek Regional WWTF was removed and land applied during the period of November 4, 2023, to December 21, 2023. The amount applied during that period totaled 4,775.9 dmt. JCW appropriately sampled the biosolids six times during the application period instead of a bi-monthly schedule. 8 Table 1, JCW Mill Creek Regional WWTP 2024 Sludge Quality (mg/kg) Pollutant Ceiling EQ Max Mo. Avg. Max/Ceiling Avg./EQ Arsenic, As 75 41 8.6 8.6 11.47% 20.98% Cadmium, Cd 85 39 3.2 3.2 3.76% 8.21% Copper, Cu 4300 1500 135 135 3.14% 9.00% Lead, Pb 840 300 20.7 20.7 2.46% 6.90% Mercury, Hg 57 17 0.5 0.5 0.88% 2.94% Molybdenum , Mo 75 ---- 12.8 12.8 17.07% Nickel, Ni 420 420 23.3 23.3 5.55% 5.55% Selenium, Se 100 36 9.6 9.6 9.60% 26.67% Zinc, Zn 7500 2800 499 499 6.65% 17.82% The table above indicates that sludge generated from the Mill Creek WWTP is well below the ceiling limits for all metals. Douglass Smith Middle Basin (DSMB) WWTP, in 2024 produced 1,487.82 dmt of Class B sludge through anaerobic digestion. All generated sludge was hauled, and land applied by a third-party hauler. Staff of the JCW indicated that the Middle Basin WWTF staff and laboratory expected to land apply more sludge in 2024 than what ended up being disposed of. As such, JCW took six (6) bi-monthly samples, which ended up being 2 more than were required by 40 CFR 503.16 based on the sludge quantity. After typing in the total land applied sludge volume for 2024, there were not enough "compliance monitoring event" rows shown in the webform. In the past, JCW was instructed to average the pollutant concentrations so that the information would be able to fit into the form. In order to maintain a certain level of accuracy in reducing 6 samples down to 4 entries, JCW staff calculated a weighted average. For example, in the first quarter (Compliance Monitoring Event No. 1) JCW weighted the first bi-monthly sample (Jan - Feb) at two thirds since it represented two out of three months in the quarter and weighted the second bimonthly sample (Mar - Apr) at one third since it represented one out of three months in the quarter. This same methodology was used for all entries. Table 2, DSMB WWTP 2024 Sludge Quality (mg/kg) Pollutant Ceiling EQ Max Mo. Avg. Max/Ceiling Avg./EQ Arsenic, As 75 41 5 5 6.67% 12.20% Cadmium, Cd 85 39 4 4 4.71% 10.26% Copper, Cu 4300 1500 312 312 7.26% 20.80% Lead, Pb 840 300 76 76 9.05% 25.33% Mercury, Hg 57 17 0.8 0.8 1.40% 4.71% Molybdenum , Mo 75 ---- 19 19 25.33% Nickel, Ni 420 420 48 48 11.43% 11.43% Selenium, Se 100 36 11 11 11.00% 30.56% Zinc, Zn 7500 2800 858 858 11.44% 30.64% The table above indicates that sludge generated from the DSMB WWTP is well below the ceiling limits 9 for all metals. Tomahawk Creek WWTP, in 2024 produced 1,903.68 dmt of Class B sludge through anaerobic digestion. All generated sludge was hauled, and land applied by a third-party hauler. JCW staff took six (6) bi-monthly samples. The table 3 below indicates that sludge generated from the Tomahawk Creek WWTP is well below the ceiling limits for all metals. Table 3, Tomahawk Creek WWTP 2024 Sludge Quality (mg/kg) 503 503 Pollutant Ceiling EQ Max Mo. Avg. Max/Ceiling Arsenic, As 75 41 5 5 6.67% Cadmium, Cd 85 39 3 3 3.53% Copper, Cu 4300 1500 301 301 7.00% Lead, Pb 840 300 9 9 1.07% Mercury, Hg 57 17 0.4 0.4 0.70% Molybdenum , Mo 75 ---- 11 11 14.67% Nickel, Ni 420 420 24 24 5.71% Selenium, Se 100 36 10 10 10.00% Avg./EQ 12.20% 7.69% 20.07% 3.00% 2.35% 5.71% 27.78% RECORDS MANAGEMENT JCW has done an exceptional job maintaining and managing industrial files and records. Files were found to be well maintained for at least three years. Files are kept at the program office/laboratory and are available to the public. During the file review, I observed that industrial files have all the necessary documentation. Each industrial file consists of at least 20 categories such as facility updated engineering plans, 90-day compliance reports, current permits, permit applications, inspection reports, compliance sampling and self-monitoring reports, correspondence/meeting notes, enforcement documentation, slug control plans, etc. CONCLUSION, EXPECTATIONS and RECOMMENDATIONS Overall, JCW continues to appropriately implement its approved pretreatment program. JCW's base for its program allows the pretreatment staff to effectively monitor the industrial waste streams and take necessary enforcement actions. The pretreatment staff appear to be well-trained and capable of running their approved program However, the following items are provided to ensure federal regulatory requirements applicable to the JCW pretreatment program are met: 1. During the last EPA audit, David Pratt requested that JCW continue to update their sewer use ordinance, and the enforcement response plan and with the expectation that the JCW finalize it one year from the audit which would have been January of 2023. JCW still has not submitted a final ERP or SUO to EPA and KDHE for review and comment. It is understood that much of the ERP is 10 complete (with the exception for a few modifications to the fine language) and much of the pretreatment aspects of the SUO is also complete. However, this has been an ongoing request that has yet to be completed. 2. The JCW should revise its current ordinance to comply with the general pretreatment regulation penalty structure under 40 CFR 403.8(f)(1)(vi) to ensure that JCW has the authority to seek or assess civil or criminal penalties in at least the amount of $1,000 a day for each violation by Industrial Users of Pretreatment Standards and Requirements. 3. In accordance with 40 CFR Part 122.44(j)(2)(ii), JCW must perform a written technical evaluation of the need to revise local limits under 40 CFR Part 403.5(c)(1) following NPDES permit reissuance for each WWTP. This technical evaluation is required to be done within one year of NPDES permit reissuance unless the NPDES permit identifies a separate time frame to complete the evaluation. Reviews should continue throughout the permit cycle as deemed necessary to protect the WWTPs from harmful contributions. The EPA's Local Limits Development Guidance, Chapter 7 (located on the EPA website), provides a detailed explanation of how and when to perform technical reevaluations. JCW must maintain the evaluation records so that those records can be reviewed during future PCAs, Pretreatment Compliance Inspections, or when requested by the EPA and/or KDHE. 4. The JCW continues to have a well-managed Biosolids Program. The following are recommendations provided to enhance the JCW pretreatment program: 1. Mass balance calculations should be performed separately for each WWTP by routinely collecting sewage sludge samples for metals concentrations (even if not required by 40 CFR Part 503) and tracking the amount of sludge generated (not disposed) each year. This information can help focus efforts to identify specific areas where potential unknown metal finishing type industrial users may exist or could help identify that existing users are potentially exceeding their categorical standards in between compliance sampling events. JUSTIN Digitally signed by JUSTIN KENSINGER Date: 2025.03.12 _K_E_N__S_I_N_G__E_R__0_7:_59_:4_5 -_05_'0_0'__ Justin Kensinger Pretreatment Coordinator, WD NICOLE Digitally signed by NICOLE MORAN Date: 2025.03.12 _M_O__R_A__N______1_1:_18_:2_5 _-05_'00' Nicole Moran Supervisor, WB/DWIS ATTACHMENTS 1. PCA Checklist (17 pages) 2. Biosolids documents 11 Audit Approved Pretreatment Program Date(s) of Pretreatment Compliance Audit (Audit)*: January 29-31, 2025 * The applicable sections of this form may be used to complete a Pretreatment Compliance Inspection. Control Authority: Address: Johnson County Wastewater 11811 S. Sunset Drive, Suite 1700 Olathe, KS 66061-7062 Date of Last PCI/Audit: December 6-8, 2021 NPDES Permit Number*: KS0088269 (Mill Creek) Contact: Title: Phone: Fax: Email: David Becker Environmental Technologist (913) 715-6956 (913) 645-1879 David.Becker@jcw.org State Permit Number*: Permit Expiration Date*: January 31, 2025 *Include permit numbers for primary wastewater treatment plant if the CA has more than one treatment plant. Participants CA: David Becker Stephen Briggs Dotty Harrison Name of Auditors/Inspectors: Justin Kensinger (EPA), Naji Ahmed (EPA), Steve Caspers (KDHE) Time period covered by this PCI/audit: 2024-2025 Publicly Owned Treatment Works Information For Primary Treatment Plant (Flows in Million Gallons Per Day) Design Daily Average 79.4 Actual Daily Average 55.4 Design Peak 277.5 Percent Industrial Flow 1.3% Number of Plants 7 % Combined Sewers 0 Type of Treatment at Principal Plant 2TF, 5AS, 1 Lagoon Sludge Disposal Method Land apply/Landfill Quantity (dry tons/year) 14,998 Receiving Stream Multiple PART I: PROGRAM BACKGROUND INFORMATION I.A. Approved Modifications to the Original Program 1. Date of last NPDES permit modification: Date of original program approval: Date NPDES permit originally modified to require implementation [PTIM]: 01/18/1984 2. Significant Pretreatment Program Modifications: PROGRAM MODIFICATIONS APPROVAL DATE OTHER APPROVED MODIFICATIONS APPROVAL DATE Sewer Use Ordinance* 12/11/1992 SUO Update 01/17/2003 List of SIUs [403.8(f)(6)] Continuous Enforcement Response Plan 01/15/1991 ERP Minor Update 01/17/2012 Local Limits *Includes required streamlining provisions. 04/07/2017 3. Is the CA presently working on any program modifications? Yes No If yes, please describe: ERP, SUO, Local Limits reevaluation 4. Does the CA have any significant program modifications currently being reviewed by the Approval Authority? Yes No If yes, please list those documents that are under review: I.B. Approved Program Contents 5. Describe the mechanism the program uses to give them the legal authority to enforce pretreatment requirements: Article 4 of SUO 6. Provide the date the legal authority was enacted or adopted: December 10, 1992; Updated December 19, 2002 7. Describe the control mechanism (e.g., permits, agreements, etc.) the program uses to enforce pretreatment standards: Permits Note: Italicized question numbers indicate that the question is required ICIS data elements supported. 2 8. Identify current program practices and any changes that have occurred from the original program approval: Activity CA sampling of: Noncategorical SIUs 1-4 Times/year Categorical SIUs* 1-4 Times/year Changes from Original Program CA inspection of: Annual Annual SIU self-monitoring: Daily/semi-annual Daily/semi-annual SIU reporting: * For categorical pollutants Varies Semi-annual 9. What types of enforcement options are available through the program (place an X in each applicable box). Have there been any changes from the original approval? Yes No If yes, please explain: 10. Comments: Y Notice of Violation Y Administrative Order Y Show Cause Hearing Y Establishment of Compliance Schedules Y Revocation of Permit Y Injunctive Relief Y Administrative Penalties N Civil Penalties; At Least $1,000/Day/Violation Y Criminal Penalties Y Termination of Service 3 PART II: INTERVIEW QUESTIONS II.A. Legal Authority and Jurisdiction Have any pretreatment modifications been made to the current sewer use ordinance since the last PCI/audit that have not been approved by the AA? Yes No List by name and location any significant industrial users that discharge to the CA from outlying jurisdictions. Indicate which of the listed SIUs are not covered by a contract/agreement requiring them to abide by the CA's legal authority:1$ Cintas Simmons Guns 13. Does the CA have the authority to seek civil or criminal fines of at least $1,000 per day per violation? [403.8(f)(1)(vi)] Yes No 14. Does the control authority feel they need to update their Enforcement Response Plan? Yes No If yes, please explain: Need to update the fine language and structure in accordance with 403.8(f)(1)(vi) to at least $1,000 per day per violation. They will be revising several other sections as well. 15. Comments: For Question 13: The SUO currently says that the maximum fine amount per violation per day is $2,000. There are several violations with fine amounts below $1,000. II. B. Control Mechanism Issued to SIUs 16. General Information: Type (e.g., permits/agreements): Permits Duration (i.e., in years): 5 years 17. Do all SIUs have a current (unexpired) control mechanism? {NOCM} Yes No 18. List by name those SIUs that do not have a control mechanism and indicate which SIUs have not had a current control mechanism for 180 days or more. {RNC/SNC} N/A SIUs without a control mechanism: None SIUs without a control mechanism for more than 180 days: None 4 II.C. Hauled Wastes 19. Does the CA accept hauled waste? Yes No (If no, go to question 25) a. If yes, describe (include approximate number of loads per month): 700 b. How does the CA ensure that it does not accept hazardous waste? Flash-point & pH testing 20. Does the CA have a control mechanism for regulating waste haulers, and if so, describe? Yes No N/A Licenses issued by the health department. 21. Does the CA have a designated discharge point (or points) for waste haulers? [DSS: 403.5(b)(8)] Yes No N/A If yes, describe the location: 22. Are all applicable categorical standards and local limits applied to IUs whose wastes are hauled to the CA? Yes No N/A 23. Describe the method used to apply (enforce) local limits to a hauled waste: They do not accept any categorical hauled wastes. 24. Comments: II.D. Industrial User Characterization 25. How often does the CA update its Industrial Waste Survey to identify new SIUs or changes to wastewater discharges? 1) Continuously update surveillance logs 2) New development team sends out form to new users 3) Send out industrial waste forms when they find a suspicious user a. When was the last formal update? Continuous 26. What is the CA's current industrial base? Current Number of SIUs 13 8 21 Industrial User Type Categorical SIUs {CIUS} Non-Categorical SIUs Total all SIUs {SIUS} Last Reported Number of SIUs 13 8 21 5 II.E. Local Limits 27. Does the CA have numerical limits for metals in its National Pollutant Discharge Elimination System permit? Yes No If yes, list the metals and the limits (or attach list to this checklist): 28. Identify any numerical NPDES permit violations that have occurred in the last 12 months at any of the treatment plants? None Nelson Complex Wastewater Treatment Facility - Effluent violations a. Were any of the numerical NPDES violations, identified above, a result of interference or pass through? Yes No 1. If yes, was the interference traceable to an industrial user? Yes No 2. If yes, was action taken that led to elimination within 90 days of the interference or pass through? {SNC} Yes No 3. If yes, was the responsible industry placed on an enforceable compliance schedule within 90 days of discovery? {SNC} Yes No N/A If no, why was IU not placed on a schedule? 29. How many times per year does the CA regularly sample its principal treatment plant for the following? Parameter Metals Toxic Organics Biomonitoring TCLP Influent 4/yr 0 Effluent 1 0 1 Sludge 6/yr Every 2 years HW every 2 yrs 30. List below the numerical value for the local limits derived by technical analysis. If a technical analysis was performed, but the limit was not adopted, enter DNA (did not adopt) in the block. (Values assumed to be mg/L unless otherwise noted.) {EVLL} {ADLL} 6 POLLUTANT Varies for each WWTP DAILY MAX POLLUTANT DAILY MAX 31. Are the CA's biochemical oxygen demand, total suspended solids, and ammonia local limits technically derived (i.e., based on plant capacity)? Yes No N/A 32. Are BOD, TSS and ammonia permit limit exceedances treated as violations of technically based local limits? Yes No N/A If no, please explain: 33. If there is more than one treatment plant, were local limits established specifically for each plant? Yes No 1$If no, please explain: 34. Has the CA made any changes to its local limits which have not been approved by the AA? [403.18] Yes No If yes, provide details? 35. Has the CA granted any waivers to IUs such as net/gross allowances, pollutants not present, middle tier CIUs, etc., or has the CA applied for removal credits? Yes No If yes, please describe: 1) Argenta - US Manufacturing 2) Biomune Company 3) Hennessy Research Associates, LLC 36. +DVDORFDOOLPLWVUHHYDOXDWLRQEHHQSHUIRUPHGIROORZLQJUHQHZDORIWKH13'(6SHUPLW"<HV1R,IQR 7 II.F. Standards and Requirements for IUs 37. Does the CA compare local limits against federal categorical standards and apply the most stringent standards to categorical IUs? [403.4] Yes No a. Are any IUs required to implement best management practices in lieu of monitoring for pollutants? Yes No If yes, please describe: 38. Did the CA notify its IUs of possible Resource Conservation Recovery Act obligations? [403.8(f)(2)] Yes No 39. Does the CA allow categorical users to use total toxic organics management plans/certification or surrogate test procedures to meet TTO requirements if allowed under the categorical standard? Yes No II.G. CA Compliance Monitoring and Inspections 40. What is the current frequency for: Activity CA sampling of: CA inspection of: SIU self-monitoring: SIU reporting: * For categorical pollutants Noncategorical SIUs 1/yr 1/yr Varies 12/yr & 2/yr Categorical SIUs* Varies 1/yr Varies 2/yr 41. List exceptions: 42. List those SIUs below that were not sampled by the CA within the last 12 months: [DSS: 403.8(f)(2)(v)] None 43. List those SIUs below 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 8 45. Does the CA sample its SIUs for all regulated pollutants at least once annually? [403.8(f)(2)(v)] Yes No 46. Sample/Analysis Procedures: Chain-of-Custody always used? Yes No Sampling method, metals: Grab Ability to sample on short notice? Yes No Sampling method, cyanide: Grab In-house analysis of toxic pollutants? Yes No Sampling method, oil and grease: Grab Do in-house analytical methods conform to 40 CFR part 136 (including pH)? Yes No Notes: 47. How does the CA document its industrial user inspections? Checklist and narrative format 48. Does the CA evaluate all SIUs to determine the need for a slug discharge/spill control plan? [DSS: 403.8(f)(2)(v)] Yes No a. Describe the method used by the CA to evaluate the need for a slug control plan: Asses during inspections II.H. IU Self-Monitoring and Reporting 49. Are all significant categorical IUs required to self-monitor for all pollutants regulated by the respective categorical standard at least twice per year? [403.12(e)] Yes No a. If nonsignificant categorical IUs have been identified, are they meeting all the monitoring and reporting requirements as established by the CA? Yes No N/A If no, please explain: 50. Were any baseline monitoring reports or 90 day compliance reports due within the past 12 months? Yes No If yes, from which IU and were the reports submitted as required? 51. Are IUs required to report spills, slug discharges, etc. to the CA? [403.12(f)] Yes No 52. Are IUs required to report violations within 24 hours of knowledge of the violation? [403.12(g)(2)] Yes No 53. Are IUs required to resample and submit results within 30 days following a violation? [403.12(g)(2)] Yes No 9 II.I. Data Management 54. Are files/records in electronic formats or are they in paper form, or both? 55. Are all records maintained for at least three years? [403.12(o)] Yes No 56. Are program records available to the public? [403.14(b)] Yes No 57. Does the CA have provisions to address confidential business information? [403.14(a)] Yes No 58. How is compliance status (e.g., SNC) calculated? Describe the procedure used in determining SNC as defined in 403.8(f)(2)(viii) and by the SUO? Utilize spreadsheets and it is defined in their SUO and ordinance. a. Is method used to calculate SNC appropriate? Yes No II.J. Program Resources 59. What percent of the pretreatment coordinator's time is spent on pretreatment? 40% 59. What computer programs are used to document program activities: Word Processing: MS Word Spreadsheet: Excel Database: Lablite 61. Does the CA believe its annual budget is adequate in order to implement their program? Yes No a. If no, does the CA need to devote more resources to adequately implement their program? Yes No If no, please explain: b. What is the annual operating budget? $1,351,485.00 II.K. Special Questions 62. Are there any issues that the CA would like to discuss? Yes No If so, please discuss below: 10 PART III: FILE AND RECORDS REVIEW DEFINITIONS Following is a table containing the CA's SIU 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 requested by the table with 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 "N/A" 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 1,000. 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 SIX MONTH PERIOD ENDING: For the six month periods listed, indicate the industry's compliance status. Use the following abbreviations: "C" "I" "SNC,S" "SNC,R" "SNC,M" "SNC,C" In compliance with all standards (e.g., no violations). Infrequent noncompliance with discharge standards. The facility had some violations but not severe enough to be considered in SNC. In SNC with discharge standards. In SNC with reporting requirements. The industry failed by greater than 30 days to submit reports as required. In SNC with self-monitoring requirements. The industry did not properly report its compliance status on its selfmonitoring reports. Failure to meet a compliance schedule milestone by 90 days. LAST INSPECTION: Date of the last inspection performed by the city. 11 Significant Industrial Users Johnson County, KS 2024 Industry Name Argenta US Manufacturing, LLC*** Biomune Company Central Biomedia, Inc. Deffenbaugh Industries, Inc. Disposable Instrument Company, Inc. ELC Distribution Center LLC**** Flora Food Sourcing US, Inc.** Flowers Baking Co. of Lenexa, LLC Gill Studios, Inc.***** Heartland Precision Fastners, Inc. Hennessy Research Associates, LLC (II) Inficon EDC, Inc. (II) International Flavors and Fragrances, Inc. IRCA New Century* Ivy Animal Health, Inc. Kocher + Beck USA LP Lenexa WWTP, LLC SAFC Biosciences, Inc. Sauer Brands, Inc. Sparhawk Laboratories, Inc. Tapco Products Company TED Manufacturing Corporation Universal Engraving, Inc. TMT? Batch? CWF? Cat Stnd 439NS 439ES, 439NS 439ES NA 433ES NA Regulated Process PHARM PHARM PHARM LANDFILL ELECPOLSH PAINTMANU Treatment Type Y pH ADJ/FLT/CAS/UV/ELCHOXI N NA Y pH ADJ N NA Y PRCP/FLT/pH ADJ N NA NA EDIBL OIL Y DAF/pH ADJ NA Bakery NA PRINTING 433NS NiZnCrPL 439NS 469ES PHARM QTZCRYST NA FOODEMUL NA CHOCFOOD 439ES 433NS NA 439ES NA 439ES PHARM CHEMTECH IPTPLANT PHARM EDIBL OIL PHARM NA COMLAUND Y FLT/ph ADJ Y FLT Y PRCP/FLT/pH ADJ N NA Y FLT/pH ADJ Y DAF/pH ADJ Y DAF/pH ADJ Y pH ADJ y PRCP/FLT/pH ADJ Y ANBIOFLT Y pH ADJ Y DAF/pH ADJ Y Activated Carbon Y FLT/pH ADJ 433ES AgAuCuNiPL 433NS CHEMETCH Y PRCP/FLT/pH ADJ Y PRCP/FLT/pH ADJ Regulated Flow, 1000 gpd 45.7 92.6 0.2 8.6 0.1 0.4 80.2 3.2 0 6.9 4.1 1.8 153.1 0.0 0.001 2.2 109.2 15.1 55.3 26.3 21.2 1 0.6 Total Flow, 1000 gpd N 71.9 N Compliance Status for the Six Month Period Ending: Jun 2023 Dec 2023 Jun 2024 Dec 2024 C C C C Last Inspection CY2024 4/23/2024 N 106.9 N C C C C 10/17/2024 Y 0.3 N C C C C 10/3/2024 N 8.6 NA C C C C 9/17/2024 N 0.3 N C C C C 6/27/2024 N 3 NA C C I-Reporting C SNC- SNCN 102.4 NA Reporting Reporting, I- I-O&G C O&G SNC- SNCN 5.5 NA Reporting I-O&G, I-pH Reporting, I- C pH N 0 NA I-Reporting C Permit N/A cancelled N 8 N SNC-Cd, I-Cu, C I-pH, I-Cd, I- C I-Ni Cu N 4.6 N C C C C 3/12/2024 5/9/2024 7/16/2024 2/8/2024 7/30/2024 5/2/2024 Y 2.3 N C N 156.1 NA I-pH Y 0.0 NA C Y 0.09 N C C C C 1/18/2024 SNC- C Reporting, I- C 6/25/2024 O&G C C Permit 1/18/2024 cancelled C C C 11/5/2024 Y 3.4 N C I- Reporting C C 4/11/2024 N 110.3 NA C C SNC-BOD I-BOD 1/9/2024 N 19.3 N C I- Reporting C C 8/27/2024 N 59.2 NA I- Reporting C C I-pH 2/6/2024 N 28.5 N N 21.5 NA Y 2.1 N Y 2.1 N C C C SNC- C Reporting, I- I-pH pH SNC-CN, I-pH, C SNC- C Reporting, I- Reporting C C C C 11/14/2024 I-pH 9/26/2024 I-pH 2/29/2024 C 8/6/2024 *****Gill Studios, Incorporated's permit was cancelled, due to no reasonable potential for adversely affecting POTW's operation or for violating any Pretreatment Standards. **** Excelligence Learning Corp. has changed it's name to ELC Distribution Center LLC ***TriRx Shawnee, LLC. was purchased and is now known as Argenta US Manufacturing, LLC. **Upfield Sourcing US, Inc. has changed it's name to Flora Food Sourcing US, Inc. *IRCA New Century's permit was cancelled due to the facility shuting down. Number of SIUs: 21 Number of CategoriCal SIUs: 13 Number of Non-CategoriCal SIUs: 8 69. Were all enforcement actions taken by the CA within 30 days of knowledge of a violation? {RNC/SNC} Yes No 70. Did all industries in SNC either return to compliance within 90 days, receive escalated enforcement action by the CA within 90 days, or become placed on an enforceable compliance schedule within 90 days (of knowledge by the CA) of the violation? {RNC/SNC} Yes No N/A If no, please explain: III.C. Control Mechanism Evaluation 71. Do the CA's control mechanisms contain the following? Y = yes; N = no; N/A = not applicable Permit Evaluated: REQUIRED [DSS: 403.8(f)(1)(iii)] SUGGESTED PROVISIONS Specify duration (not > 5 years): Y Cite the CA's legal authority: Y Contain the correct discharge limits: Y Identify TTO alternatives, if applicable: NA Specify sample type for IU self-monitoring: Y Require notification within 24 hours 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 Other? Are the current control mechanisms adequate? Yes No If no, please explain: III.D. Industrial Inspection Evaluation 72. Do the industrial inspection reports contain? Y = yes; N = no; N/A = not applicable Name of company contact: Y Evaluation of IU's monitoring procedures: Y Date of inspection: Y Verification of wastewater flow rates: N Time of inspection: Y Determination of applicability of the CWF: Y Description of manufacturing process: Y 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 Verification of production rates that would affect production based standard: NA Is the inspection report form complete? Yes No If no, please explain: 14 III.E. Slug/Spill Control Plans 73. If the CA has required the submittal of a slug/spill control plan, does it contain the following: [DSS: 403.8(f)(2)(v)] (Note: All the items below must be checked for the plan to be considered complete.) N/A ___Y___ A description of discharge practices including non-routine batch discharges to city sewer. ___Y___ A description of stored liquids/chemicals onsite. ___Y___ Procedures for immediate notification of slug or accidental discharges with written follow-up notification to the CA. ___Y___ Procedures necessary to prevent adverse effects at the CA's treatment plant or collection system. ___Y___ Procedures for inspection and maintenance of chemical storage areas: ___Y___ Proper handling and transferring of materials and liquids. ___Y___ Adequately loading and unloading liquids and materials. ___Y___ Adequately controlling pollutants from leaving the plant site. ___Y___ Providing training on spill response for employees. ___Y___ Inspecting containment structures. ___Y___ Providing measures for the control of toxic pollutants. ___Y___ Implementing procedures for emergency response to spills. ___Y___ Providing adequate spill response equipment onsite. PART IV: ADDITIONAL INFORMATION IV.A. Fats, Oil and Grease Program 74. Is there an established FOG program? Yes No N/A If yes, describe the program: a. How many sanitary sewer overflow occur on average each year? b. Are any SSOs caused by FOG or by any other type of industrial discharge? Yes No If yes, please explain: IV.B. Dental Amalgam Rule, Part 441 Requirements 75. How many dental dischargers have been identified by the CA? Have all dental dischargers that are served by the POTW submitted a one-time compliance report to the CA? Yes No a. If no, please explain: b. Have treatment devices been installed when applicable? Yes No If no, please explain: c. Is the CA continuing to identify and monitor new dental dischargers or changes in ownership? Yes No 15 III.H. IU File Review Checklists Following are worksheets to aid in the assessment of the nature of the oversight activities and compliance status of the CA's SIUs. 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 best available treatment 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 CAs. 16 Industry Name: Flowers Baking Company Principal Pollutants of Concern: Oil and Grease Products: Bread No. of Employees: 239 A. Does the file system for the industrial user contain the following items (Mark "Y" for Yes, "N" for No or "N/A" for not applicable: ___Y__ ___Y__ ___Y__ ___Y__ ___Y__ ___Y__ ___Y__ Completed permit application ___Y__ Current (active) permit ___Y__ Correct limits in permit ___Y__ Correspondence/meeting notes/phone log __N_A__ Most recent inspection report __N_A__ Evaluation for need for slug/spill control plan ___Y__ Compliance status determination (e.g., SNC, I, C) CA compliance sampling results Self-monitoring reports Enforcement documentation, if applicable Solvent management plan, if applicable Correct application of the CWF Copy of slug/spill control plan, if required B. Did the industry discharge any slug loads or spills to the CA in the past 12 months [403.12(f)]? Yes No If yes: __N_A__ Was there immediate notification by the IU? __N_A__ Follow-up written notification by IU? __N_A__ Did the CA respond? __N_A__ Adverse effect on treatment plant? C. In the last complete calendar year, how many times did the CA do the following [403.8(f)(2)(v)]: Sample the IU ___1___ Inspect the IU ___1___ D. Were all regulated pollutants in the IU's permit analyzed by the CA at least once in the most recent calendar year [403.8(f)(2)(v)]? Yes No E. If the industry is subject to categorical standards, did their self-monitoring reports contain analysis for all regulated pollutants at least once during every six month period during the last full calendar year [403.12(e)(1)]? Yes No If no, please explain: F. Frequency in the IU's control mechanism for: Self-monitoring 1X/2WKS/DLY ______ Reporting _S_em_i-a_nn_ua_l G. Did the industry comply with the sampling and reporting frequency requirements of its control mechanism? Yes No If no, please explain: 2 reporting periods of SNC-R (JUN23&JUN24) H. Did the CA identify all IU violations from: IU Self-monitoring ___Y___ CA compliance monitoring ___Y___ I. Was the IU's compliance status (e.g., SNC, Infrequent noncompliance, Consistent compliance) determined properly? Yes No If no, please explain: J. Complete the following table for all violations in the last 12 months: (If this information has already been provided above, please indicate.) Date Date of ERP Type of Date of CA Knew CA's Required Actual CA Violation Violation of Violation Response Response Response Type 17