ࡱ> q bjbjt+t+ cAA|f]rrrrrrr$PT:t z ( 4`rtttttt$i]r0"00rr 2B 20r r rrrrr0rz 'rrr  <`D{wm8`Pretreatment Compliance Audit Summary Report Discharger: City of Colton Location: 1201 South Rancho Avenue, Colton, California 92324 Contact(s): William Roth, Wastewater Utility Manager Mark Solano, Environmental Compliance Mark Perales, Assistant Wastewater Utility Manager Inspection Date: February 12, 2003 Inspected By: Najah Amin, California Regional Water Quality Control Board Chuck Durham, Tetra Tech, Inc. I-Hsin Lee, Tetra Tech, Inc. Michelle Ittes, Tetra Tech, Inc. Mary Diesel, Tetra Tech, Inc. Contents  TOC \o "1-3" \h \z  HYPERLINK \l "_Toc49586844" 1. Executive Summary  PAGEREF _Toc49586844 \h 1  HYPERLINK \l "_Toc49586845" 2. Introduction  PAGEREF _Toc49586845 \h 1  HYPERLINK \l "_Toc49586846" 2.1 Size of Program  PAGEREF _Toc49586846 \h 2  HYPERLINK \l "_Toc49586847" 2.2 Description of the Wastewater Treatment Plant  PAGEREF _Toc49586847 \h 2  HYPERLINK \l "_Toc49586848" 3. Pretreatment Program Modification  PAGEREF _Toc49586848 \h 2  HYPERLINK \l "_Toc49586849" 4. Local Limits  PAGEREF _Toc49586849 \h 3  HYPERLINK \l "_Toc49586850" 5. Legal Authority  PAGEREF _Toc49586850 \h 3  HYPERLINK \l "_Toc49586851" 5.1 Contributing Jurisdictions  PAGEREF _Toc49586851 \h 3  HYPERLINK \l "_Toc49586852" 5.2 Grand Terrace SUO  PAGEREF _Toc49586852 \h 4  HYPERLINK \l "_Toc49586853" 6. Nondomestic Discharger Characterization  PAGEREF _Toc49586853 \h 4  HYPERLINK \l "_Toc49586854" 6.1 Significant Industrial Users  PAGEREF _Toc49586854 \h 4  HYPERLINK \l "_Toc49586855" 6.2 Identification of Nondomestic Dischargers  PAGEREF _Toc49586855 \h 4  HYPERLINK \l "_Toc49586856" 7. Control Mechanisms  PAGEREF _Toc49586856 \h 4  HYPERLINK \l "_Toc49586857" 7.1 Statement of Non-Transferability  PAGEREF _Toc49586857 \h 5  HYPERLINK \l "_Toc49586858" 7.2 Record-Keeping Requirements  PAGEREF _Toc49586858 \h 6  HYPERLINK \l "_Toc49586859" 7.3 Civil and Criminal Penalties  PAGEREF _Toc49586859 \h 6  HYPERLINK \l "_Toc49586860" 7.4 Notification of Significant Change  PAGEREF _Toc49586860 \h 6  HYPERLINK \l "_Toc49586861" 7.5 TTO Certification  PAGEREF _Toc49586861 \h 6  HYPERLINK \l "_Toc49586862" 7.6 Local Limit Concentrations  PAGEREF _Toc49586862 \h 7  HYPERLINK \l "_Toc49586863" 8. Application of Pretreatment Standards and Requirements  PAGEREF _Toc49586863 \h 7  HYPERLINK \l "_Toc49586864" 9. Compliance Monitoring  PAGEREF _Toc49586864 \h 7  HYPERLINK \l "_Toc49586865" 9.1 Compliance Sampling  PAGEREF _Toc49586865 \h 7  HYPERLINK \l "_Toc49586866" 9.2 Compliance Inspections  PAGEREF _Toc49586866 \h 7  HYPERLINK \l "_Toc49586867" 9.3 Nondomestic Discharger Site Inspections Conducted During the Audit  PAGEREF _Toc49586867 \h 8  HYPERLINK \l "_Toc49586868" 9.4 Slug Discharge Control Plans  PAGEREF _Toc49586868 \h 9  HYPERLINK \l "_Toc49586869" 10. Enforcement  PAGEREF _Toc49586869 \h 9  HYPERLINK \l "_Toc49586870" 11. Receiving and Analyzing Reports  PAGEREF _Toc49586870 \h 9  HYPERLINK \l "_Toc49586871" 12. Summary of Findings, Requirements, and Recommendations  PAGEREF _Toc49586871 \h 10  Attachments Attachment A Water Enforcement National Database (WENDB) Worksheet Attachment B Reportable Noncompliance (RNC) Worksheet Attachment C Nondomestic Discharger Information: Angelica Rental Service Group Attachment D Nondomestic Discharger Information: Jon-Lin, Inc. Attachment E Nondomestic Discharger Information: Telco Food & Products, Inc. Attachment F Nondomestic Discharger Information: Williams Furnance Attachment G Nondomestic Discharger Site Visit Data Sheets Attachment H Ordinance No. 0-03-98 1. Executive Summary The Santa Ana Regional Water Quality Control Board (Regional Board), with assistance from Tetra Tech, Inc., conducted a Pretreatment Compliance Audit (PCA) of the City of Colton (City) on February 12, 2003. The Citys last PCA had been performed by the U.S. Environmental Protection Agency (EPA) in 1990. The Regional Board has conducted Pretreatment Compliance Inspections (PCIs) annually since the EPA audit in 1990. This audit report identifies the primary concerns generated by the PCA conducted on February 12, 2003. The Citys pretreatment program consists of one categorical industrial user (CIU) subject to federal pretreatment standards, four noncategorical significant industrial users (SIUs), and seven other regulated nonsignificant nondomestic dischargers. There are two contributing jurisdictions, the City of Grand Terrace and unincorporated areas of San Bernardino County. City personnel appear to have a good general understanding of the pretreatment requirements and the inspectors seem to have a thorough knowledge of the nondomestic users. In a number of areas, however, the program is in need of improvement. One concern is that the City personnel could not verify the basis for local limit development. Another concern is that the multijurisdictional agreement with the City of Grand Terrace has expired. Concerns regarding the discharge permits include the absence of the statement of non-transferability, record-keeping requirements, a statement of applicable civil and criminal penalties, and the notification requirements for significant changes. Other concerns are that monitoring reports are not certified and the nondomestic dischargers do not submit the chain-of-custody forms to the City. Finally, it appears that the City is not documenting the evaluation of whether nondomestic dischargers need to develop and implement slug discharge control plans. 2. Introduction The PCA consisted of three portions: an interview with the City representatives; a review of the pretreatment program files; and site visits of various permitted industries. The interview portion included a discussion regarding the program in general, compliance sampling and inspection procedures, frequencies, and enforcement issues. The file review consisted of reviewing the files of four nondomestic dischargers. To provide a general overview of the pretreatment program, the files were selected based on the classifications of the nondomestic dischargers. The following files were reviewed during the audit: Williams Furnace (CIU subject to 40 CFR 433.15) Jon-Lin, Inc. (SIU) Angelica Rental Service Group (SIU) Telco Food & Products, Inc. (SIU) Two permitted dischargers were also inspected as part of this audit. Inspectors from the Regional Board and Tetra Tech, Inc., accompanied the inspectors from the City to assess whether inspection procedures were adequate. To ensure a representative cross section of the Citys pretreatment program, the selection of discharger for inspection was based on classification. The following dischargers were visited during the audit: Williams Furnace (CIU subject to 40 CFR 433.15) Telco Food & Products, Inc. (SIU) This report summarizes the overall findings of the audit and describes those program elements that are not consistent with federal pretreatment program requirements. In addition, the report provides recommendations to enhance the effectiveness of program implementation and enforcement. 2.1 Size of Program The Citys pretreatment program consists of 12 permitted nondomestic dischargers, all located within the City. Four of these dischargers are classified as SIUs as defined at 40 CFR 403.3(t). There is one CIU subject to the federal categorical pretreatment standards at 40 CFR 433.15. The City also permits seven nonsignificant nondomestic dischargers. 2.2 Description of the Wastewater Treatment Plant The City operates one wastewater treatment plant (WWTP). The City of Grand Terrace and unincorporated areas of San Bernardino County are contributing jurisdictions to the WWTP. In 1996 the City began to discharge secondary treated wastewater from the WWTP to the ColtonSan Bernardino Regional Tertiary Treatment and Water Reclamation Authoritys Regional Tertiary Treatment Rapid Infiltration and Extraction Facility (RIX) located in Colton. 3. Pretreatment Program Modification 40 CFR 403.18 requires the City to notify the Regional Board of any modifications it intends to make to its pretreatment program, sewer use ordinance (SUO), or enforcement response plan (ERP). The modifications would include changes in SIU classifications, local regulations, and clarification of nondomestic discharger permit language. The Regional Board must approve any substantial modifications before the City may implement them. Substantial modifications include modifications that relax the Citys legal authorities, changes that relax local limits, changes to the Citys control mechanisms, a decrease in the frequency of self-monitoring or reporting required for nondomestic users, a decrease in the frequency of SIU compliance sampling and inspections, changes to the Citys confidentiality procedures, and any other modifications the Regional Board designates as substantial. The City must submit nonsubstantial modifications to the Regional Board for review at least 45 days prior to implementation. The City plans to revise its SUO within the next calendar year to incorporate a rate structure for nondomestic discharger fees. The Citys current SUO was adopted on February 17, 1998; the ERP was adopted on April 19, 1994. According to City personnel, the rates will be based on sewage strength. Other modifications will include identifying the total dissolved solids (TDS) local limit and regulating commercial water softeners. The City is required to notify the Regional Board of any modifications it intends to make to its pretreatment program prior to implementation as specified at 40 CFR 403.18. 4. Local Limits The pretreatment regulations at 40 CFR 403.5(c) require publicly owned treatment works (POTWs) to develop and enforce local limits to implement the general and specific prohibitions at 40 CFR 403.5(a) and (b). The pretreatment regulations also require POTWs to continue to develop these local limits as necessary and effectively enforce the limits. Furthermore, the National Pollutant Discharge Elimination System (NPDES) regulations at 40 CFR 122.44(j)(2)(ii) require POTWs to provide a written technical evaluation of the need to revise local limits following permit issuance or reissuance. City personnel were unable to determine the basis for local limit development. According to the personnel, the City had hired an outside contractor to evaluate the Citys local limits in 1989. No copy of the results of the evaluation was available at the time of the audit. It is recommended that the City retain a copy of the local limit development document on-site and evaluate that document to determine the limiting criteria. 5. Legal Authority 40 CFR 403.8(f) requires that every POTW subject to the national pretreatment program have the necessary legal authority to apply and enforce section 307(b) and (c) and section 402(b)(8) of the Clean Water Act. 5.1 Contributing Jurisdictions City personnel indicated that the multijurisdictional agreement between the City and the City of Grand Terrace has expired. 40 CFR 403.8(f)(1) requires the City to have the legal authority to enact and implement its pretreatment program in contributing jurisdictions. The City has contributing jurisdictional agreements with the unincorporated areas of the San Bernardino County. The Citys multijurisdictional agreements have given the City the authority to permit, inspect, sample, and conduct enforcement actions each nondomestic discharger within the City as well as the contributing jurisdictions. According to City personnel, they have had no any problems exercising their legal authority to implement and enforce the Citys pretreatment program. The City is required to renew the multijurisdictional agreement with the City of Grand Terrace as a contributing jurisdiction to ensure compliance with the pretreatment program regulations at 40 CFR 403.8(f)(1). 5.2 Grand Terrace SUO Whether Grand Terraces SUO mirrors the Citys SUO or has been updated to comply with the requirements in 40 CFR Part 403 is unknown. City personnel were unable to obtain a copy of the Grand Terrace SUO. The City of Grand Terrace is a contributing jurisdiction to the Citys WWTP. It is recommended that the City obtain a copy of the Grand Terrace SUO to determine whether the document is in compliance with 40 CFR Part 403. 6. Nondomestic Discharger Characterization The pretreatment regulations at 40 CFR 403.8(f)(2) require that POTWs develop and implement procedures to identify and locate nondomestic dischargers that might be subject to the local pretreatment program. These procedures must also include proper categorization of all SIUs as defined at 40 CFR 403.3(t). 6.1 Significant Industrial Users The Citys definition of an SIU mirrors the definition in the federal pretreatment regulations (at 40 CFR 403.3(t)) as any nondomestic discharger subject to a categorical pretreatment standard, or any noncategorical nondomestic discharger discharging greater than 25,000 gallons per day of process wastewater or greater than 5 percent of the total influent loading or volume to the WWTP. 6.2 Identification of Nondomestic Dischargers The City is required to implement procedures to enable it to identify and locate all possible nondomestic dischargers that might be subject to the pretreatment program. The City is also required to identify the character and volume of pollutants contributed to its sewerage system by nondomestic dischargers as described at 40 CFR 403.8(f)(2)(i) and (ii). The Citys procedures for identifying nondomestic dischargers appear to be adequate. According to City personnel, the Planning and Building Department distributes a questionnaire that must be completed along with the business license permit application. A nondomestic discharge permit application is provided to the new business if needed. The City is responsible for storm water compliance, and therefore the City conducts frequent inspections at numerous nondomestic facilities. According to City personnel, the nondomestic facilities potential for nondomestic wastewater discharge is evaluated at the time of the inspections. The City personnel also perform routine and drive-by inspections. 7. Control Mechanisms The pretreatment regulations at 40 CFR 403.8(f)(1)(iii) require POTWs to control through a permit (or other similar means) the discharge from nondomestic dischargers to ensure compliance with applicable pretreatment standards. The control mechanisms (permits) are required, at a minimum, to include the following: Statement of duration (in no case more than 5 years) Statement of non-transferability Effluent limits Self-monitoring, sampling, reporting, and record keeping requirements Statement of penalties Compliance schedules (if applicable) Required resampling within 30 days after a notice of a violation Notification requirements Notice of slug loadings Notification of spills, bypasses, or upsets Notification of significant change in discharge 24-hour notification after a notice of a violation Permits for CIUs must also properly use the combined wastestream formula, properly convert mass-based limits to concentration-based limits, properly apply production-based limits (if applicable), and must include a prohibition on dilution as a substitute for treatment. The following is the evaluation of Citys control mechanisms and the permitting process. More detailed discussions of the findings are provided in Sections 7.1 through 7.6 of this report. None of the permits reviewed include the required statement of non-transferability, record-keeping requirements, statement of applicable civil and criminal penalties, and notification requirements for significant changes. The discharge permit issued to Williams Furnace indicates that total toxic organic (TTO) sampling has been waived. The required TTO certification, however, has not been submitted to the City. The discharge permit issued to Jon-Lin requires that the industry sample for mercury. The SUO, however, does not specify a local limit for mercury. In the discharge permit, the local limit for the maximum concentration of selenium is incorrect. Statement of Non-Transferability 40 CFR 403.8(f)(1)(iii)(B) specifies that a nondomestic discharger may not transfer its existing discharge permit to any new owner or operator. None of the discharge permits reviewed indicate that the discharge permits are non-transferable. The City is required to modify all discharge permits to include the statement of non-transferability as specified at 40 CFR 403.8(f)(iii)(B). 7.2 Record-Keeping Requirements 40 CFR 403.12(o)(2) specifies that any nondomestic discharger must retain any records of monitoring activities and results for a minimum of 3 years. None of the discharge permits reviewed include this record-keeping requirement. The City is required to modify all discharge permits to include the record-keeping requirements as specified at 40 CFR 403.12(o)(2). 7.3 Civil and Criminal Penalties 40 CFR 403.8(f)(1)(iii)(E) requires that all SIU permits contain an applicable statement of civil and criminal penalties for violation of pretreatment standards and requirements. None of the discharge permits reviewed contain statements of applicable civil and criminal penalties. The City is required to modify all discharge permits to include the statement of applicable civil and criminal penalties as specified at 40 CFR 403.8(f)(1)(iii)(E). 7.4 Notification of Significant Change 40 CFR 403.8(f)(1)(iii) requires that all nondomestic discharge permits include the requirement to notify the City of slug discharges, spills, bypasses, upsets, and significant changes to discharges. None of the permits reviewed contain the notification requirements. The City is required to modify all discharge permits to include the required notification of slug discharges, spills, bypasses, upsets, and significant changes to discharge as required by 40 CFR 403.8(f)(1)(iii). 7.5 TTO Certification Williams Furnace, a CIU subject to 40 CFR 433.15, has not submitted the required semiannual TTO certifications. The dischargers permit indicates that TTO sampling has been waived. 40 CFR 403.12(e) requires all CIUs to submit semiannual reports indicating the nature and concentration of pollutants that are regulated by categorical pretreatment standards. Furthermore, 40 CFR 433.12 indicates that in lieu of monitoring for TTO, the discharger may certify that there has been no dumping of concentrated toxic organics into the wastewater since the filing of the last discharge report and that the facility is implementing the toxic organic management plan (TOMP). The City is required to revise Williams Furnaces discharge permit to require semiannual TTO sampling or the submission of semiannual TTO certifications as specified at 40 CFR 403.12(e). Furthermore, if the City requires the submission of semiannual certifications, the discharger is required to submit a TOMP to the City for review and approval before the certifications are implemented, as specified at 40 CFR 433.12. 7.6 Local Limit Concentrations The Citys SUO does not include a local limit for mercury. Jon-Lins discharge permit, however, requires that the discharger must sample for and comply with a mercury limit. Tetra Tech, Inc., is unclear how this concentration limit was developed. The discharge permit also includes an incorret the local limit for selenium. The discharge permit lists the local limit concentration for selenium as 0.011 milligrams per liter (mg/L) instead of the correct concentration, 0.11 mg/L, as specified in the Citys SUO. It is recommended that the City determine the basis for itsmercury limit concentration and document the findings. It is also recommended that the City modify the discharge permit issued to Jon-Lin with the correct selenium local limit concentration. 8. Application of Pretreatment Standards and Requirements The federal pretreatment regulations at 40 CFR 403.8(f)(1) state that the City must have the legal authority to require compliance with applicable pretreatment standards and requirements, and to ensure compliance with these standards and requirements through the use of control mechanisms such as permits. The City had correctly classified all other nondomestic dischargers whose files were reviewed. 9. Compliance Monitoring The pretreatment regulations at 40 CFR 403.8(f)(2)(v) require that a POTW develop and implement an inspection and monitoring program to determine, independent of information supplied by nondomestic dischargers, compliance or noncompliance with applicable pretreatment standards and requirements. Furthermore, 40 CFR 403.8(f)(2)(vi) requires POTWs to investigate instances of noncompliance and enforce the regulations as necessary. 9.1 Compliance Sampling The City is conducting adequate compliance sampling at all facilities reviewed during the audit. At a minimum, the City conducts annual compliance sampling events at all nondomestic dischargers. The City samples noncategorical SIUs and CIUs are sampled semiannually and quarterly, respectively. Furthermore, SIUs and CIUs must conduct semiannual and quarterly self-monitoring, respectively. 9.2 Compliance Inspections 40 CFR 403.8(f)(2)(v) requires that all SIUs be inspected at least once a year. The City conducts inspections of each nondomestic discharger annually. According to City personnel, if a nondomestic discharger has frequent sampling violations, inspections are performed more frequently. Two nondomestic dischargers, both located within the City, were inspected as a part of this audit. In general, the Citys inspection reports are thorough and complete. The Citys inspectors are knowledgeable of the pretreatment requirements and familiar with the dischargers. The Citys compliance inspection procedures were found to be adequate. 9.3 Nondomestic Discharger Site Inspections Conducted During the Audit The audit team, along with City personnel, inspected two of the permitted nondomestic dischargers as part of this audit. The dischargers were selected to represent facilities of varying size and classification. A list of the dischargers selected for inspections is provided in Section 2 of this report. The Tetra Tech inspection team noted the following during the nondomestic discharger site visits: Williams Furnace Company: The discharger manufactures gas-fired wall furnaces, decorative gas appliances, fan coils, and air handlers. The production portion of the facility was found to be clean and organized. During the inspection, however, several deficiencies were noted. Although the dischargers representative indicated that self-monitoring takes place six times a year, the results of only two sampling event results were submitted to the City in 2002. At the time of the inspection, the discharger was unable to provide a copy of its current discharge permit or a current hazardous waste manifest. A copy of the current discharge permit was provided to the City after the inspection had been completed. Finally, a pH meter had not been installed as recommended by the Regional Board after the last PCI conducted. 40 CFR 403.12(g)(5) requires that if a nondomestic discharger monitors any pollutant more frequently than required by the City using the procedures set forth at 40 CFR Part 136, those results must be submitted to the City. The City is required to ensure that Williams Furnace Company is submitting all self-monitoring results. If the discharger fails to comply with the requirements at 40CFR 403.12(g)(5), the City is required to take appropriate enforcement actions. In addition, it is strongly recommended that the discharger install a pH meter at its sampling location to ensure compliance with pH limits. Telco Food Products, Inc.: The discharger produces packaged bakery products. The production portion of this discharger was not inspected because of security issues. Only the external portion of the pretreatment system was observed. During the inspection, the representative indicated that the current combined flow is 180,000 gallons per day. The current discharge permit, however, specifies the required maximum daily flow as 60,000 gallon per day. This discharger is working on decreasing its oil and grease concentrations by using experimental enzymes. The City is required to either change the dischargers flow requirements to reflect the current combined flow of 180,000 gallons per day, or enforce the flow limits specified in the dischargers current permit. 9.4 Slug Discharge Control Plans 40 CFR 403.8(f)(2)(v) requires the City to evaluate, at least once every 2 years, whether each SIU needs to develop and implement a slug discharge control plan. Williams Furnace has not been evaluated since the initial slug discharge control plan was submitted with the original permit application dated February 22, 1991. No documentation for slug discharge evaluations at any time during the past 2 years was found for Telco Foods, Jon-Lin, and Angelica Rental Service Group. The City is required to evaluate, at least once every 2 years, whether each SIU is required to develop and implement a slug discharge control plan as defined at 40 CFR 403.8(f)(2)(v). The City is also required to provide the results of these evaluations to the Regional Board upon request. 10. Enforcement 40 CFR 403.8(f)(5) requires the City to develop and implement an ERP. This plan must contain detailed procedures indicating how the City will investigate and respond to instances of industrial user noncompliance. The Citys current ERP was submitted to the Regional Board and adopted on April 19, 1994. The ERP was also adopted by all contributing jurisdictions. The City is not enforcing reporting violations. Jon-Lin and Angelica Rental Service Group submitted only one self-monitoring report during 20012002. The permits of Jon-Lin and Angelica Rental Services Group require the dischargers to submit semiannual self-monitoring reports. In addition, Williams Furnace is submitting semiannual reports rather than the required quarterly reports. The City is required to take appropriate enforcement actions as outlined in its approved ERP for all instances of noncompliance. Furthermore, the City is required to publish all SIUs in significant noncompliance (SNC) for failure to provide self-monitoring reports within 30 days after the due date [40 CFR 403.8(f)(2)(vii)(F). 11. Receiving and Analyzing Reports 40 CFR 403.6(a)(2)(ii) requires that all self-monitoring reports have a certification statement signed by an authorized representative. None of the self-monitoring reports reviewed have the required signed certification statement. 40 CFR 403.12(l) requires that all CIU self-monitoring reports be certified and signed by an authorized representative. The City is required to ensure that all self-monitoring reports are signed and certified as specified at 40 CFR 403.6(a)(2)(ii) and 40 CFR 403.12(l). For all files reviewed, the audit team determined that chain-of-custody forms were not being submitted with self-monitoring reports. Without the chain-of-custody forms, it is not possible to determine whether samples were collected and preserved property and whether holding times have been exceeded. It is recommended that the City require that chain-of-custody forms be submitted with all self-monitoring reports. 12. Summary of Findings, Requirements, and Recommendations Listed below are the primary requirements and recommendations resulting from the audit of the Citys pretreatment program. For more specific information pertaining to each comment, please refer to the relevant sections of the report (as referenced). The City plans to revise its SUO within the next calendar year. The City is required to notify the Regional Board of any modifications it intends to make to its pretreatment program prior to implementation as specified at 40 CFR 403.18. (3. Pretreatment Program Modification) City personnel were unable to determine the basis for local limit development. It is recommended that the City retain a copy of the local limit development document on-site and evaluate the document to determine the limiting criteria. (4. Local Limits) City personnel indicated that the multijurisdictional agreement with the City of Grand Terrace had expired. The City is required to renew the multijurisdictional agreement with the City of Grand Terrace as a contributing jurisdiction to ensure compliance with the pretreatment program regulations at 40 CFR 403.8(f)(1). (5.1 Contributing Jurisdictions) City personnel were unable to provide a copy of Grand Terraces SUO. It is recommended that the City obtain a copy of that SUO to determine whether it is in compliance with 40 CFR Part 403. (5.2 Grand Terrace SUO) None of the discharge permits reviewed indicate that the discharge permit is non-transferable. The City is required to modify the discharge permits issued to include the statement of nontransferability as specified at 403.8(f)(1)(iii). (7.1 Statement of Non-Transferability) None of the discharge permits reviewed include the record-keeping requirements. The City is required to modify all discharge permits to include the record-keeping requirements as specified at 40 CFR 403.12(o)(2). (7.2 Record-Keeping Requirements) None of the discharge permits reviewed contain statements of applicable civil and criminal penalties. The City is required to modify all discharge permits to include the statement of applicable civil and criminal penalties as specified at 40 CFR 403.8(f)(1)(iii)(E). (7.3 Civil and Criminal Penalties) None of the discharge permits reviewed contain the notification requirements. The City is required to modify the discharge permits to include the required notification of slug discharges, spills, bypasses, upsets, and significant changes to the discharge as required by 40 CFR 403.8(f)(1)(iii). (7.4 Notification of Significant Change) Williams Furnace has not been submitting the required semiannual TTO certifications. The City is required to revise Williams Furnaces discharge permit to include semiannual TTO sampling or the submission of semiannual TTO certifications as defined at 40 CFR 403.12(e). Furthermore, if the City requires the submission of semiannual certifications, the discharger is required to submit a TOMP to the City for review and approval prior to the implementation of the certifications as specified at 40 CFR 433.12. (7.5 TTO Certification) The Citys SUO does not include a local limit for mercury, but the City requires nondomestic dischargers to sample and to comply with a mercury limit. It is recommended that the City determine the basis for mercury limit concentration and document the findings. (7.6 Local Limit Concentrations) The discharge permit issued to Jon-Lin contains an incorrect selenium local limit. It is recommended that the City modify the discharge permit issued to Jon-Lin with the correct selenium local limit concentration. (7.6 Local Limit Concentrations) Williams Furnace has not submitted all monitoring results to the City. 40 CFR 403.12(g)(5) requires that if a nondomestic discharger monitors any pollutant more frequently than required by the City using procedures set forth at 40 CFR Part 136, those results must be submitted to the City. The City is required to ensure that Williams Furnace Company submits all self-monitoring results. If the discharger fails to comply with the requirements at 40 CFR 403.12(g)(5), the City is required to take appropriate enforcement actions. (9.3 Nondomestic Discharger Site Inspections Conducted During the Audit) Williams Furnace has not installed a pH meter as recommended by the Regional Board. It is strongly recommended that the discharger install a pH meter at its sampling location to ensure compliance with pH limits. (9.3 Nondomestic Discharger Site Inspections Conducted During the Audit) Telco Foods is discharging wastewaters in excess of its permit limits. The City is required to either change the dischargers flow requirements to reflect the current combine flow of 180,000 gallons per day or enforce the flow limits in the dischargers current permit. (9.3 Nondomestic Discharger Site Inspections Conducted During the Audit) The City is not conducting slug control plan evaluations at least once every 2 years. The City is required to evaluate each SIU, at least once every 2 years, to determine whether the SIU needs to develop and implement a slug discharge control plan as defined at 40 CFR 403.8(f)(2)(v). (9.4 Slug Discharge Control Plans) The City is not enforcing reporting violations. The City is required to take appropriate enforcement responses, as outlined in its approved ERP, for all instances of noncompliance. Furthermore, the City is required to publish all SIUs in SNC for failure to provide self-monitoring reports within 30 days after the due date [40 CFR 403.8(f)(2)(vii)(F). (10. Enforcement) None of the self-monitoring reports reviewed have the required signed certification statement. The City is required to ensure that all self-monitoring reports are signed and certified as specified at 40 CFR 403.6(a)(2)(ii) and 40 CFR 403.12(l). (11. Receiving and Analyzing Reports) Chain-of-custody forms are not being submitted to the City. It is recommended that the City require that chain-of-custody forms be submitted with all self-monitoring reports. (11. 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