ࡱ> M mbjbj== `WWBinl$ TTTP@ 1V.(VVVb!V##P$# C@B$  |B$B$@ %VVU| % % %B$:VV %B$ % %-`V @:j & 4T|$Rb\\ѝ`1Ӣ$RӢ % Pretreatment Compliance Inspection Summary Report Discharger: City of Colton Location: 1201 .South Rancho Avenue, Colton, California 92324 Contact: Gary Ethridge, Consultant, G&G Environmental Compliance, Inc. Inspection Date: February 25, 2004 Inspected By: Najah Amin, Regional Water Quality Control Board Chuck Durham, Tetra Tech, Inc. Michelle Ittes, Tetra Tech, Inc. Contents  TOC \o "1-5" \h \z  HYPERLINK \l "_Toc69538340" 1. Executive Summary  PAGEREF _Toc69538340 \h 1  HYPERLINK \l "_Toc69538341" 2. Introduction  PAGEREF _Toc69538341 \h 1  HYPERLINK \l "_Toc69538342" 2.1 Size of Program  PAGEREF _Toc69538342 \h 2  HYPERLINK \l "_Toc69538343" 2.2 Description of the Citys Wastewater Treatment Plant  PAGEREF _Toc69538343 \h 2  HYPERLINK \l "_Toc69538344" 3. Pretreatment Program Modifications  PAGEREF _Toc69538344 \h 2  HYPERLINK \l "_Toc69538345" 4. Nondomestic Discharger Characterization  PAGEREF _Toc69538345 \h 3  HYPERLINK \l "_Toc69538346" 5. Control Mechanisms  PAGEREF _Toc69538346 \h 3  HYPERLINK \l "_Toc69538347" 6. Application of Pretreatment Standards and Requirements  PAGEREF _Toc69538347 \h 4  HYPERLINK \l "_Toc69538348" 7. Compliance Monitoring  PAGEREF _Toc69538348 \h 4  HYPERLINK \l "_Toc69538349" 7.1 Compliance Sampling  PAGEREF _Toc69538349 \h 4  HYPERLINK \l "_Toc69538350" 7.2 Compliance Inspections  PAGEREF _Toc69538350 \h 5  HYPERLINK \l "_Toc69538351" 7.3 Nondomestic Discharger Site Inspections Conducted During the Inspection  PAGEREF _Toc69538351 \h 5  HYPERLINK \l "_Toc69538352" 7.4 Requesting, Receiving, and Analyzing Reports  PAGEREF _Toc69538352 \h 6  HYPERLINK \l "_Toc69538353" 7.5 Slug Discharge Control Plans  PAGEREF _Toc69538353 \h 6  HYPERLINK \l "_Toc69538354" 8. Enforcement  PAGEREF _Toc69538354 \h 7  HYPERLINK \l "_Toc69538355" 9. Summary of Findings, Requirements, and Recommendations  PAGEREF _Toc69538355 \h 8  Attachments Attachment A WENDB Data Worksheet Attachment B RNC Data Worksheet Attachment C Nondomestic User Information: Williams Furnace Attachment D Nondomestic User Information: Telco Food & Products Attachment E Nondomestic Discharger Site Visit Data Sheets Attachment F Instructions for Completing a Wastewater Discharge Permit Application Attachment G Ordinance No. 0-03-98 Attachment H Joint Powers Agreement Attachment I Enforcement Response Plan 1. Executive Summary The Santa Ana Regional Water Quality Control Board (Regional Board), with assistance from Tetra Tech, Inc., conducted a Pretreatment Compliance Inspection (PCI) of the City of Colton (City) on February 25, 2004. The last Pretreatment Compliance Audit (PCA) of the Citys pretreatment program had been performed in February 2003. The City has hired G&G Environmental Compliance, Inc., to manage the pretreatment program, and, for the purpose of this report, employees of this company will be considered members of City staff. The pretreatment program consists of five permitted nondomestic dischargers. Four of these dischargers are classified as significant industrial users (SIUs), and one of the SIUs is a categorical industrial users (CIUs). There are five other regulated nonsignificant nondomestic dischargers consisting of food processors and a medical disposal facility. There are two contributing jurisdictions to the City: that include the City of Grand Terrace and unincorporated areas of San Bernardino County. The members of the staff have a good general grasp of the pretreatment requirements and have a thorough knowledge of the nondomestic users. The City should be commended for the noticeable improvement in the pretreatment program over the lpast year. In a number of areas, however, the program is still in need of improvement. One concern is that the categorical industrial userCIU discharge permits fail to address procedures to be followed when a resampling event occurs in the same month that the violation occurred and how the results are to be applied for compliance. In addition, signed certification statements are not being included in the self-monitoring reports submitted to the City. Finally, slug discharge control plan evaluations performed during the inspections are poorly documented on the inspection forms, and the City is has not providing reviewed and responsded to plans submitted by the industrial facilities. 2. Introduction The PCI consisted of three parts: an interview of the Citys staff, a review of the pretreatment program files, and site visits to two permitted industries. The interview included a discussion with a member of the Citys staff regarding the program in general, the Citys compliance sampling and inspection procedures and their frequency, and enforcement issues. The file review consisted of examining the files of two nondomestic dischargers. To provide a general overview of the pretreatment program, the files were selected based on the classifications of the nondomestic dischargers. The files of the following dischargers were reviewed during the PCI: Williams Furnace, Inc. (CIU subject to 40 CFR Part 433) Telco Food & Products, Inc. (Noncategorical SIU) The same two permitted dischargers were also inspected as part of this inspection. Tetra Tech, Inc., accompanied the City staff to assess whether inspection procedures were adequate. This report summarizes the overall findings of the inspection 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 five permitted nondomestic dischargers. Four of these dischargers are classified as significant industrial users (SIUs), and one of the SIUs is a categorical industrial users (CIUs). There are five other permitted nonsignificant nondomestic dischargers consisting of food processors and a medical disposal facility. 2.2 Description of the Citys Wastewater Treatment Plant The City owns and operates the wastewater treatment facility (WWTF). The City of Grand Terrace and unincorporated areas of San Bernardino County are contributing jurisdictions to the WWTF. This secondary WWTF treatment process consists of screening and grit removal, followed by primary clarification, biological oxidation, secondary clarification, and chlorination. The sludge is disposed of at a designated landfill site. The City discharges up to 5.3 million gallons per day of secondary treated municipal wastewater to the Rapid Infiltration-Extraction (RIX) Facility. The RIX facility is a regional tertiary treatment facility owned by a joint powers authority, which includes the City of Colton and the City of San Bernardino. 3. Pretreatment Program Modifications The federal pretreatment regulations at 40 CFR 403.18 require the City to notify the Regional Board of any modifications it intends to make to its pretreatment program. After the fiscal year begins July 1, 2004, the City is plansning on to re-evaluatinge local limits. Based on aA recent evaluation of the local limit development document, it was found that local limits were not uniform and were developed based on industry- specific information. The City is considering reviewing parameters that have no technical basis. The City has no is not currently plannings onto makinge any changes to its sewer use ordinance (SUO) or enforcement response plan (ERP). It should be noted that any changes to the local limits resulting in the relaxation of criteria is considered a substantial modification, and, as a result, the City will be required to notify the Regional Board prior tobefore adoptingion and implementationing of these modifications to the pretreatment program as defined in 40 CFR 403.18. 4. Nondomestic Discharger Characterization The federal pretreatment regulations at 40 CFR 403.8(f)(2) require that publicly owned treatment works (POTWs) develop and implement procedures to identify and locate industrial users 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). The inspection team found the Citys procedures for identifying nondomestic dischargers to be adequate. According to City personnel, the City reviews a list of industrial sewer use accounts and industrial water accounts. This City is also involved in the approval for of all business development and upgrade permits. In the past, there has been a communication gap between the City and the Development Board. The City staff indicated that they are planning on getting to become involved and being present during attend the Planning Development meetings. 65. Control Mechanisms The federal pretreatment regulations at 40 CFR 403.8(f)(1)(iii) require POTWs to control through control mechanisms (permits or other similar means) the discharges from nondomestic dischargers to ensure compliance with applicable pretreatment standards. The control mechanisms are required, at a minimum, to include the following: Statement of duration (in no case more than 5 years) Statement of nontransferability Effluent limits Self-monitoring, sampling, reporting, and record-keeping requirements Statement of penalties Compliance schedules (if applicable) Required resampling within 30 days after noticing a violation Notification requirements Notice of slug loadings Notification of spills, bypasses, or upsets Notification of significant change in discharge Notification within 24 hours after noticing a violation Permits for CIUs must also properly use the combined wastestream formula, properly convert mass-based limits to concentration-based limits, and properly apply production-based limits (if applicable) and must include a prohibition on dilution as a substitute for treatment. In general, the Citys permits contained the minimum federal requirements. The permits were well written and easy to follow. The following issue was identified during the file review. The discharge permit issued to Williams Furnace listed local and categorical limits correctly with the more stringent value identified in bold. The comparison, however, is made not just with between local verseus categorical, but also with between daily maximum verseus monthly average. In the event of a sampling violation and the re-sampling event occurred in the same month, an evaluation of compliance would apply to both monthly average and daily maximum limits. It is recommended that the permit language be modified to address procedures to be followed when a resampling event occurs in the same month that the violation occurred and how the results are to be applied for compliance. 76. Application of Pretreatment Standards and Requirements The federal pretreatment regulations at 40 CFR 403.8(f)(1) require the City to 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 interview and the file reviews found that the City has applied all applicable pretreatment standards and requirements. Williams Furnace has been in operation since 1916 and is currently classified as a CIU in accordance with 40 CFR 433.15 pretreatment standards for existing sources (PSES). Based on information provided during the inspection, this facility has experienced tremendous growth since beginning operations. Specifically, the Toxic Organic Management Plan (TOMP) identifies addition of new product manufacturing in 1959 and again in 1986. Any process changes or construction occurring after 1983 would potentially justify reclassification as a new source under 40 CFR 433.15. The City is required to evaluate the details of all modifications that have occurred since 1983 to determine if whether reclassification is necessary. 87. Compliance Monitoring The federal 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. 87.1 Compliance Sampling The federal pretreatment regulations at 40 CFR 403.8(f)(2)(v) require that all SIUs be sampled at least once a year. Based on the review of the permit files and interviews with City personnel, the City conducts compliance sampling at all SIUs more frequently than what is required. The Citys compliance sampling frequency was found to be adequate. 87.2 Compliance Inspections The federal pretreatment regulations at 40 CFR 403.8(f)(2)(v) require that all SIUs be inspected at least once a year. The review of the permit files and interviews with City personnel found that the City conducts compliance inspections at all SIUs more frequently than what is required. The inspection forms, however, poorly document the any industrys need for a slug discharge control plan. This concern is discussed in more detail in Section 8.5 of this report. The Citys compliance inspection frequency was found to be adequate. 87.3 Nondomestic Discharger Site Inspections Conducted During the Inspection The inspection team, along with City personnel, inspected two of the permitted nondomestic dischargers as part of the inspection. The dischargers were selected to represent facilities of varying size and classification. The Tetra Tech inspection team noted the following during the nondomestic discharger site visits: Telco Food & Products: The facility is a producer of packaged bakery products. The dischargers operations include mixing, baking, freezing, and packaging of fresh baked goods including muffins, cakes, and pie shells for supermarket retail stores throughout the United States. Raw ingredients include flour, eggs, butter, fruit, nuts, and sugar. The process area inspected consisted of several automated cake lines where batter is added to cake pans, the cakes are baked, and iced, and the final product is packaged. The production room was found to be clean and organized. The new retention, settling, and aeration tanks were observed. They are currently not yet in operation. The compliance schedule issued in the revised permit is discussed in more detail in Section 9 of this report. The tanks will allow the wastewater discharged from production to cool, solids to settle, and oil and grease to separate. The solids and oil and grease removed from the tank will be hauled off -site. Aeration introduced prior to discharge should reduce biochemical oxygen demand levels. The industry facility is initiating this new pretreatment process based in accordance with on the compliance order identified in their its discharge permit for multiple oil and grease violations. No deficiencies were found during the inspection. Williams Furnace, Inc. The facility manufactures gas -fired wall furnaces, decorative gas appliances, fan coils, and air handlers. Operations include material handling (which includes metal stamping, forming, and assembly), production systems (including automated equipment to move the products to various locations throughout the facility), quality control testing, product painting, storage, and shipping/receiving facilities. There are several plating baths containing phosphate. Plating baths No. 1 and 3 are capped off and, therefore, cannot be drained or discharged to the WWTP. Once a year these plating baths are pumped and hauled off-site. The rinse tanks are manually monitored for pH on a regular baseis and records are kept. At the time of the inspection the final discharge point was manually monitored for pH and the result equaled 6.5. There are two automated spray booths where powder painting of the final product takes place. No deficiencies were noted during the inspection. It is strongly recommended, however, that the discharger install a pH meter at the sampling location to ensure compliance with pH limits. This is in accordance with previous requests by the Regional Board. 87.4 Requesting, Receiving, and Analyzing Reports 40 CFR 403.8(f)(2)(iv) requires the City to request, receive, and analyze all reports submitted by SIUs. The City conducts all compliance sampling at all SIUs at a minimum of once annuallyat least once a year. The City requires CIUs to perform self-monitoring and submit a Self -Monitoring Report (SMR) to the City on a quarterly basis. All SIUs are to perform self-monitoring and submit an SMR to the City semiannually. Based on the review of Telco Food & Products file, they arecompany has not includinged the signed certification statement as a part of the SMR as defined in their its nondomestic dischargers permit. The City is required to ensure that Telco Food & Products is includinges the signed certification statement along with their its semiannual SMR as described in their its nondomestic dischargers permit. 87.5 Slug Discharge Control Plans 40 CFR 403.8(f)(2)(v) requires the City 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. A slug discharge is any discharge of a nonroutine, episodic nature, including an accidental spill or noncustomary batch discharge [40 CFR 403.8(f)(2)(v)]. The City has revised its inspection form, as recommended in the exit interview of the last PCA, to include the evaluation of the dischargers need for a slug discharge control plan. The inspection team found the revised inspection form to be inadequate. The form consisted only of a check box indicating a YES or N/A regarding slug plan requirements. In addition, there are no procedures in place to follow up with the discharger to ensure that a slug plan was submitted to the City if deemed necessary based on an inspection. It is recommended that the City revise the inspection form to have allow additional space tofor provide detailed notes regarding the dischargers requirements to submit a slug discharge control plan or for provide information on the evaluation of the existing plan conducted during the inspection. In addition, it is recommended that the City have procedures in place to follow up with the discharger to ensure that they it submits a slug discharge control plan if required. The City should be commended for the development and implementation of the new Industrial Wastewater Discharge Permit Application. Section J of the permit application addresses all the requirements for a slug discharge control plan as defined in 40 CFR 403.8(f)(2)(v). Having The inclusion of this section included in the new application requires all new nondomestic dischargers coming into the pretreatment program, as well as all nondomestic dischargers going through the renewal process, to provide the City with a slug discharge control plan. This modified permit application, in conjunction with the recommended changes to the inspection form, should ensure that the City meets the requirements as described in 40 CFR 403.8(f)(2)(v). Williams Furnace submitted a Toxic Organic Management and Slug Response Plan dated November 10, 2003. The City responded in writing to Williams Furnace on November 13, 2003. The response, however, did not approve or deny disapprove the slug discharge control plan. As part of this PCI, the plan was reviewed by a member of the Tetra Tech staff and found to meet the requirements of 40 CFR 403.8(f)(2)(v). It is recommended that the plan be reviewed by the City review the plan, and approved or denied disapprove it, and notifyin writing to Williams Furnace in writing. A copy of the response from the City to Williams Furnace needs to be forwarded to the Regional Board. 98. 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 Regional Board approved the Citys ERP in 1994. The ERP has been adopted by all contributing jurisdictions. It was identified in tThe previous PCA conducted found that the City had not been following the guidelines for enforcement actions as defined in the Citys its ERP. Based on a file review of Telco Food & Products, Inc., the City issued a Notice of Violation (NOV) on January 21, 2003, to Telco Food & Products, Inc.The discharger for failure to adhere to pollutant limitations for resampling, to submit required wastewater resampling analysis, and to submit wastewater flow records, andas well as for violation of oil & and grease limits as defined in the discharge permit that took place on June 20, 2002, and December 10, 2002. Compliance monitoring took place on January 3, 2003, and self-monitoring took place on July 21, 2003. There was no evidence that notification or resampling took place. In addition, flow records from April 2003 through September 2003 indicate increased flow violations. Telco Food & Products, Inc., is in chronic significant noncompliance (SNC) for oil & and grease violations, for failure to resample, and for increased flow. As a result, this facilitys violations should be published in the local newspaper. The City responded by revising the discharge permit issued to Telco Foods & Products, Inc., on November 25, 2003. The revised permit issued includes a compliance schedule to for submitting a corrective action plan by March 1, 2004, to stop all discharges to the sewer that are in violation of oil and grease limitations by March 1, 2004. The permit also requires compliance with the new flow capacity of 150,000 gallons per day. Based on information obtained during this PCI, Telco Foods & Products, Inc., rescheduled the original compliance meeting date of February 19, 2004, to March 11, 2004. It was found that the City is now following the enforcement guidelines set forth in the Citysits ERP. It is recommended that the City ensure that the compliance schedule as defined in the discharge permit issued to Telco Food & Products is amended with any new compliance schedule dates set forth in any future compliance meetings conducted. 109. Summary of Findings, Requirements, and Recommendations Listed below are the primary requirements and recommendations resulting from the inspection of the Citys pretreatment program. For more specific information pertaining to each comment, please refer to the cited sections of the report. The City is planning onplans to re-revaluateing local limits. Any changes to the local limits resulting in the relaxation of criteria is considered a substantial modification, and, as a result, the City will be required to notify the Regional Board prior to before adoptiong and implementationing of these modifications to the pretreatment program as defined in 40 CFR 403.18. (Section 3, Pretreatment Program Modifications) The discharge permit issued to Williams Furnace should be modified to address procedures to be followed when a resampling event occurs in the same month that the violation occurred and how the results are to be applied for compliance. (Section 6, Control Mechanisms) Williams Furnace has been in operation since 1916 and is currently classified as a CIU in accordance with 40 CFR 433.15 PSES. Based on information provided during the inspection, this facility has experienced tremendous growth since beginning operations. Any process changes or construction occurring after 1983 would potentially justify reclassification as a new source under 40 CFR 433.15. The City is required to evaluate the details of all modifications that have occurred since 1983 to determine if whether reclassification is necessary. (Section 7, Application of Pretreatment Standards and Requirements) Williams Furnace currently has approval from the City to continue to monitor pH manually at the discharge point on a periodic basis. In accordance with the previous requests by the Regional Board, it is strongly recommended that a continuous pH meter should be installed at the discharge location to ensure continued compliance with pH limits. (Section 8.3, Nondomestic Discharger Site Inspections) Telco Food & Products are has not includinged the signed certification statement as a part of their the SMR submitted to the City as required by their its discharge permit. Thise City is required to ensure that the certification statement is included in the semiannual SMR submitted to the City by Telco Food & Products. (Section 8.4, Requesting, Receiving, and Analyzing Reports) The City now evaluates the need for slug discharge control plans is now being evaluated by the City during each inspection conducted.; Hhowever, the documentation of these evaluations was found to be inadequate. The form only consists of only a check box and there is no method in place for follow-up in the event a plan is required. It is recommended that the City revise the inspection form to include additional space to provide for detailed notes regarding the dischargers requirement to submit a slug plan or provide for information on the evaluation of the existing plan in place. In addition, it is recommended that the City have procedures in place to follow up with the discharger to ensure that they it submits a slug discharge control plan if during the inspection such a plan is found to be required by the inspection. (Section 8.5, Slug Discharge Control Plans) Williams Furnace submitted Aa slug discharge control plan was submitted to the City by Williams Furnace on November 10, 2003. The plan was adequate,; however, the written response from the City only commended the plan, but did not officially approve it. It is recommended that the City review the slug discharge control plan submitted to the City by Williams Furnace, be reviewed by the City and either approved or denied disapprove it, notify Williams Furnace in writing, and forward a copy of the response forwarded to the Regional Board. (Section 8.5, Slug Discharge Control Plans) The discharge permit issued to Telco Food & Products has includeds a compliance schedule for flow, and oil and grease compliance. Meetings are taking place regarding the time line for compliance. The original permit indicates a plan must be in place by March 1, 2004. It is recommended to the City that the discharge permit issued to Telco Food & Products be amended with any new compliance schedule dates set forth in any future compliance meetings conducted. 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