ࡱ> %  bjbj%% UGG}}l$   P\T p (6 6 6 >#f%X&\$ ǡ(&""|&&(p+6 6 =<p+p+p+&r6 6 p+&p+lp+.ʓLn6 d kX\  &(ZnyHpW)xWnp+ Pretreatment Compliance Inspection Draft Summary Report Discharger: City of Colton Location: 1201 South Rancho Avenue, Colton, California 92324 Contact(s): Gary Defreeze, Consultant, G&G Environmental Compliance, Inc. Benjamin Ethridge, Consultant, G&G Environmental Compliance, Inc. Inspection date: March 12, 2005 Inspected by: Michelle Ittes, Tetra Tech, Inc. Steve Hruby, Tetra Tech, Inc. Contents TOC \o "1-5" \h \z   HYPERLINK \l "_Toc103736530" 1. Executive Summary  PAGEREF _Toc103736530 \h 1  HYPERLINK \l "_Toc103736531" 2. Introduction  PAGEREF _Toc103736531 \h 1  HYPERLINK \l "_Toc103736532" 2.1 Size of Program  PAGEREF _Toc103736532 \h 2  HYPERLINK \l "_Toc103736533" 2.2 Description of the Citys Wastewater Treatment Plant  PAGEREF _Toc103736533 \h 2  HYPERLINK \l "_Toc103736534" 3. Pretreatment Program Modifications  PAGEREF _Toc103736534 \h 2  HYPERLINK \l "_Toc103736535" 4. Local Limits  PAGEREF _Toc103736535 \h 2  HYPERLINK \l "_Toc103736536" 5. Nondomestic Discharger Characterization  PAGEREF _Toc103736536 \h 3  HYPERLINK \l "_Toc103736537" 6. Control Mechanisms  PAGEREF _Toc103736537 \h 3  HYPERLINK \l "_Toc103736538" 7. Application of Pretreatment Standards and Requirements  PAGEREF _Toc103736538 \h 4  HYPERLINK \l "_Toc103736539" 8. Compliance Monitoring  PAGEREF _Toc103736539 \h 4  HYPERLINK \l "_Toc103736540" 8.1 Compliance Sampling  PAGEREF _Toc103736540 \h 5  HYPERLINK \l "_Toc103736541" 8.2 Compliance Inspections  PAGEREF _Toc103736541 \h 5  HYPERLINK \l "_Toc103736542" 8.3 Nondomestic Discharger Site Visits Conducted During the PCI  PAGEREF _Toc103736542 \h 5  HYPERLINK \l "_Toc103736543" 8.4 Requesting, Receiving, and Analyzing Reports  PAGEREF _Toc103736543 \h 6  HYPERLINK \l "_Toc103736544" 8.5 Slug Discharge Control Plans  PAGEREF _Toc103736544 \h 7  HYPERLINK \l "_Toc103736545" 9. Enforcement  PAGEREF _Toc103736545 \h 8  HYPERLINK \l "_Toc103736546" 10. Data Management  PAGEREF _Toc103736546 \h 8  HYPERLINK \l "_Toc103736547" 11. Summary of Findings, Requirements, and Recommendations  PAGEREF _Toc103736547 \h 9  Attachments Attachment A Water Enforcement National Database (WENDB) Worksheet Attachment B Reportable Noncompliance (RNC) Worksheet Attachment C Nondomestic Discharger Information: Telco Foods, Inc. Attachment D Nondomestic Discharger Information: Arrowhead Medical Hospital Attachment E Nondomestic Discharger Site Visit Data Sheets Attachment F Significant Noncompliance Publication 1. Executive Summary The Santa Ana Regional Water Quality Control Board (Regional Water Board), with assistance from Tetra Tech, Inc., conducted a Pretreatment Compliance Inspection (PCI) of the City of Colton (City) on March 12, 2005. The last PCI of the Citys pretreatment program was performed in February 2004. This inspection report describes the primary concerns generated by the recent PCI. The City has contracted G&G Environmental Compliance, Inc., to manage its pretreatment program, and for the purpose of this report, employees of this consulting firm are considered members of the City staff. The pretreatment program consists of five permitted significant industrial users (SIUs): four dischargers are noncategorical SIUs, and one discharger is a categorical industrial user (CIU). There are five other regulated nonsignificant nondomestic dischargers, which consist of food processors and a thermal combustion innovator. The members of the City staff appeared to have a good general grasp of the pretreatment requirements, and the City inspectors seemed to have a thorough knowledge of their respective nondomestic users. The City should be commended for the continued improvement of its pretreatment program. In a number of areas, however, the program is in need of improvement. In general, the Citys permits require a minor revision. The discharge permits reviewed did not include the complete list of local limits to be analyzed in the event a full screening is required. In other areas, dischargers self-monitoring reports have not been signed and certified and self-monitoring events have not taken place during the periods specified in the discharge permits. In addition, one industry is not notifying the City within 24 hours following a discharge violation. Finally, one slug discharge control plan submitted to the City did not contain all the minimum requirements. 2. Introduction The PCI consisted of three parts: an interview with City staff, a review of the pretreatment program files, and site visits to two permitted industries. The interview included a discussion with members of the City 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 several nondomestic dischargers. To provide a general overview of the pretreatment program, the files were selected on the basis of the classifications and compliance status of the nondomestic dischargers. The files of the following dischargers were reviewed during the PCI: Telco Food Products (noncategorical SIU) Arrowhead Medical (noncategorical SIU) Two permitted dischargers were also inspected as part of this PCI. Inspectors from Tetra Tech, Inc., and the Regional Water Board accompanied the City inspectors to assess whether inspection procedures were adequate. To ensure a representative cross section of the Citys pretreatment program, the dischargers were selected for inspection on the basis of classification and current compliance status. The facilities of the following dischargers were visited during the PCI: Telco Food Products (noncategorical SIU) Williams Furnace (CIU subject to Title 40 of the Code of Federal Regulations [CFR] Part 433) 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 pretreatment program consists of five permitted SIUs: four dischargers are noncategorical SIUs, and one discharger is a CIU. There are five other regulated nonsignificant nondomestic dischargers, which consist of food processors and a thermal combustion innovator. 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. The 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 that 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 Water Board of any modifications it intends to make to its pretreatment program. The City has no plans to make any changes to its sewer use ordinance (SUO) or enforcement response plan (ERP). During the interview, City personnel indicated that the City plans to reevaluate its local limits. Please see Section 4 for detailed information. 4. Local Limits The federal 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 and reissuance. The City plans to reevaluate its local limits, possibly in 2005. As discussed in the previous PCI, an evaluation of the local limit development document found that the local limits were not uniform and had been developed based on individual industry-specific information. The City discussed reviewing parameters that have no technical basis. The City is reminded that any change to the local limits resulting in the relaxation of criteria is considered a substantial modification. As a result, the City will be required to notify the Regional Water Board before adopting and implementing these modifications to the pretreatment program, as specified at 40 CFR 403.18. 5. Nondomestic Discharger Characterization The federal pretreatment regulations at 40 CFR 403.8(f)(2) require that 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 adequate. The City participates in the business plan check process. All commercial facilities are sent an industrial waste survey to be completed and returned to the City. The City also reviews all utility requests. Information provided on the survey is used to determine whether the facilities should be included in the pretreatment program. The City also reviews the phone book and newspapers for new businesses. The City plans to conduct an inspection survey of all businesses in its jurisdiction to determine whether any additional industries should be a permitted as part of the pretreatment program in 2005. 6. 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. For each permit reviewed, Part 1, Discharge Requirements Discharge Limitation Table, which contains the list of local limits, did not include selenium as a local limit parameter as identified in the Citys SUO. Selenium is not a pollutant of concern for either discharger; however, if the City were to conduct a full screening of the local limits, the industry would not be aware that selenium is a required parameter. The Tetra Tech inspection team recommends that the discharge permits reviewed be revised to include selenium on the list of local limits. 7. 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. Based on information obtained during the previous PCI, the City was required to evaluate the details of the modifications that have occurred at Williams Furnace to determine whether the industry needed to be reclassified as a new source under 40 CFR 433.17. The City indicated that after further investigation of the processes at Williams Furnace, the discharge will remain an existing source under 40 CFR 433.15. This decision was presented to the Regional Water Board, which agreed with the decision. 8. 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. 8.1 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. The City conducts compliance sampling at each of its SIUs semiannually. The inspection team found the compliance sampling frequency adequate. 8.2 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 City currently conducts inspections at each of its SIUs semiannually. In the event that a discharger is in noncompliance with pretreatment standards, additional inspections may be conducted. The inspection team found the compliance inspection frequency adequate. 8.3 Nondomestic Discharger Site Visits Conducted During the PCI The Tetra Tech inspection team and the Regional Water Board, along with City personnel, inspected two of the permitted nondomestic dischargers as part of the PCI. 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. Operations at Telco Food Products primarily include mixing, baking, freezing, and packaging of bakery products for distribution at regional supermarkets. The production, packaging, and shipping areas at the facility were well organized and well maintained. Hazardous materials handled on-site include ammonia (used in refrigeration) and detergents and caustics (used for cleaning equipment and production areas). The hazardous materials were properly stored in sealed 55-gallon drums within secondary containment and overhead cover. Manifests for the proper disposal and recycling of hazardous materials were maintained on-site. The facility is working with an engineering consultant to construct flow equalization and settling tanks to comply with requests from the City of Colton. The facility representative indicated that a significant contribution to the increased flow is the result of improper wastewater specifications on the recently installed automated baking lines. The automated machines produce approximately 10 to 20 gallons per minute of wastewater; however, the specifications of the machines indicate approximately 2 gallons per minute of wastewater discharge. The Tetra Tech inspection team recommends that the City conduct follow-up inspections to ensure that the wastewater discharged from the automated baking lines is not a form of waste dilution. Williams Furnace. The City has classified Williams Furnace as a CIU with operations that include sheet metal fabrication, welding, powder coating, and space-heater component assembly. Hazardous materials handled on-site are primarily acid rinse solutions and petroleum-based cutting oils. These materials are properly handled, stored, and disposed of by a certified hazardous waste hauler. Metal components are cleaned with an acidic wash and rinsed with fresh water prior to entering the powder coating process. The acid rinse is captured and continuously recycled, and rinse water is directed to a sampling port prior to discharge to the POTW. At the time of the inspection, the facility was working toward manufacturing a batch release tank to adequately maintain compliance for pH in the discharge to the POTW. The wastewater treatment system and batch release tank are in the west side of the manufacturing building. No deficiencies were noted at the time of the inspection. 8.4 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 Tetra Tech inspection team reviewed the files for Telco Foods and Arrowhead Medical as a part of this PCI. In both permits reviewed, Part 3, Reporting Requirements, states that all monitoring reports submitted to the City of Colton must include a signed certified statement. The monthly flow records submitted to the City did not contain this required certification statement. The City is required to ensure that all monitoring reports, including the monthly flow records, include the signed certification statement as required by the discharge permit. In addition, no dates of receipt were found on the reports. The discharge permits require that all flow records be submitted to the City by the 15th of the following month. Because the dates on which the reports were received could not be determined, the inspection team could not determine whether the dischargers were in compliance with their reporting requirements. The Tetra Tech inspection team recommends that the fax cover sheets be retained with the flow records or that the date of receipt be identified on each report so that whether the reports were submitted by the required date can be determined. The discharge permit for Telco Foods requires that the discharger conduct self-monitoring within the first 10 days of April and October. The analytical results reviewed in the file indicate that Telco Foods has conducted self-monitoring in January and July. This schedule, according to City staff, was the sampling requirement specified in a previous discharge permit. The Tetra Tech inspection team recommends that Telco Foods, as well as the dischargers contracting laboratory, be notified of the change in sampling requirements. The City is reminded that if a discharger does not comply with its monitoring requirements, it is in violation of its discharge permit and enforcement action should be taken. The discharge permit for Telco Foods states in Part 3, Reporting Requirements, Section A, Monitoring Reports, that all required monitoring results shall be summarized and reported on a Self Monitoring Report Form provided by the City of Colton. In addition, the discharge permit requires that all monitoring reports submitted to the City of Colton must include a Signed Certified Statement. The file review indicated that Telco Foods has not submitted the Self Monitoring Report Form with the analytical results or the required signed certified statement as required by the dischargers permit. The City is required to ensure that all self-monitoring reports include the Self Monitoring Report Form and the signed certified statement as required in the discharge permits. If a self-monitoring report does not include the required form or certification statement, the City is required to taken enforcement actions as specified in its ERP. The inspection team reviewed Arrowhead Medicals file as a part of this PCI. The discharge permit, Part 2, Monitoring Requirements, Section A, states that all required monitoring shall be completed within the first ten days of January, April, July, and October. Sampling events conducted by the discharger occurred on March 22, June 30, and September 14, 2004. The City is required to ensure that self-monitoring events occur according to the schedule specified in the discharge permits. If the self-monitoring events are not taking place as required, enforcement action must be taken as specified in the ERP. The Tetra Tech inspection team recommends that if the self-monitoring event schedule has changed, the discharge permit should be revised to reflect the change and each discharger should notify its respective contracting laboratory of the revised self-monitoring schedule. The self-monitoring report certification form for Telco Foods did not identify all the required parameters listed in the dischargers permit. The City has developed a self-monitoring certification form that must be submitted with the certified laboratory results. Each form is designed specifically for each individual discharger and identifies the required parameters to be sampled in a self-monitoring event. Telco Foods form did not identify copper, cyanide, lead, selenium, zinc, fluoride, iron, or manganese as pollutants to be sampled; however, these pollutants are identified in the dischargers permit as pollutants of concern and must be sampled. The Tetra Tech inspection team recommends that the City revise the self-monitoring report certification form for Telco Foods to reflect the pollutants to be monitored for during a self-monitoring event as identified in the industrys discharge permit. 8.5 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 uses a slug discharge control plan criteria outline to assist staff when reviewing a plan to ensure that the minimum requirements have been met. The slug discharge control plan for Telco Foods was submitted to the City as required. Use of the outline showed that the plan did not meet the minimum requirements; however, the file contained no additional documentation that the industry had been notified and required to submit a revised slug discharge control plan. The City is required to ensure that all slug discharge control plans submitted meet the minimum federal requirements. In addition, the inspection team reviewed the slug discharge control plan criteria outline and found that it did not meet the minimum federal requirements specified at 40 CFR 403.8(f)(2)(v). The outline did not specify that the slug discharge control plan should include a description of discharge practices, a chemical inventory list, and a written follow-up within 5 days after the occurrence of a slug event. The Tetra Tech inspection team recommends that the City revise the slug discharge control plan criteria outline to specify the minimum federal requirements. 9. 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 Tetra Tech inspection team found the City to be adequately complying with its ERP for effluent violations. Telco Foods was in significant noncompliance for 2004 and was published in the Citys largest regional newspaper. Telco Foods has also been in noncompliance for elevated levels of oil and grease and excessive flow rates. The discharger is under a compliance order to eliminate any discharges in noncompliance with pretreatment standards and to reduce excessive flow rates. The industry has hired an engineering firm to assist in the redesign of its pretreatment system. The industry has installed aeration tanks and is experimenting with different methods of reducing oil and grease. The dates identified in the compliance order have been met and the City is working closely with Telco Foods to ensure that compliance is achieved. The Tetra Tech inspection team found, however, that the City is not adequately implementing its ERP in instances of reporting noncompliance. Because of continuous noncompliance, Telco Foods is sampling on every 14th day to closely monitor pH and oil and grease. The inspection team found no records that Telco Foods has been notifying the City within 24 hours of noticing noncompliance as required by the discharge permit and at 40 CFR 403.12(g)(2). The City is required to escalate enforcement actions, as defined in its ERP, for failure to notify the City within 24 hours of noticing noncompliance with the pretreatment standards. The Tetra Tech inspection team recommends that the City document all phone calls or other forms of noncompliance notification. In addition, the file review revealed that the City has not identified several additional instances of reporting noncompliance (as discussed in section 8.4 of this report). Therefore, the City is required to identify all instances of noncompliance and to implement the enforcement actions outlined in its ERP. 10. Data Management The City uses a database to manage all analytical results submitted by the dischargers, as well as the compliance sampling results. Upon review of the data printouts, the Tetra Tech inspection team had difficulty determining which analytical data results were from the dischargers self-monitoring and which were from the Citys compliance monitoring. The Tetra Tech inspection team recommends that an additional field be created, or that some other type of identification be included in the database, to indicate whether the data was the result of self-monitoring or compliance monitoring. 11. 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 plans to reevaluate its local limits, possibly in 2005. The City should be reminded that any change 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 before adopting and implementing these modifications to the pretreatment program, as specified at 40 CFR 403.18. (Section 4, Local Limits) The files for Telco Foods and Arrowhead Medical were reviewed as a part of this PCI. For both permits reviewed, Part 1, Discharge Requirements Discharge Limitation Table, contains the list of local limits. This list does not include selenium as a local limit parameter, as identified in the Citys SUO. The Tetra Tech inspection team recommends that the discharge permits reviewed be revised to include selenium in the list of local limits. (Section 6, Control Mechanisms) The files for Telco Foods and Arrowhead Medical were reviewed as a part of this PCI. For both permits reviewed, Part 3, Reporting Requirements, states that all monitoring reports submitted to the City of Colton must include a signed certified statement. The City is required to ensure that all monitoring reports, including the monthly flow records, include the signed certification statement as required by the discharge permit. (Section 8.4, Requesting, Receiving, and Analyzing Reports) The discharge permits require that all flow records be submitted to the City by the 15th of the following month. There were no dates of receipt on the reports in the file. The Tetra Tech inspection team recommends that the fax cover sheets be retained with the flow records or that a date received be identified on the reports so that whether the reports were submitted by the required date can be determined by the City. (Section 8.4, Requesting, Receiving, and Analyzing Reports) The discharge permit for Telco Foods requires that the discharger conduct self-monitoring within the first 10 days of April and October. According to the analytical results reviewed in the file, Telco Foods is conducting self-monitoring in January and July. The Tetra Tech inspection team recommends that Telco Foods, as well as the dischargers contracting laboratory, be notified of the change in sampling requirements. (Section 8.4, Requesting, Receiving, and Analyzing Reports) The discharge permit for Telco Foods states in Part 3, Reporting Requirements, Section A, Monitoring Reports, that all required monitoring results shall be summarized and reported on a Self Monitoring Report Form provided by the City of Colton. In addition, the discharge permit requires that all monitoring reports submitted to the City of Colton must include a Signed Certified Statement. The City is required to ensure that all self-monitoring reports include the Self Monitoring Report Form and the signed certified statement as specified in the discharge permits. (Section 8.4, Requesting, Receiving, and Analyzing Reports) Arrowhead Medicals discharge permit, Part 2, Monitoring Requirements, Section A, states that all required monitoring shall be completed within the first ten days of January, April, July, and October. Sampling events conducted by the discharger occurred on March 22, June 30, and September 14, 2004. The City is required to ensure that self-monitoring events occur on the schedule specified in the dischargers permits. The Tetra Tech inspection team recommends that if the self-monitoring event schedule has changed, the discharge permits should be revised to reflect this change and each discharger should notify its respective contracting laboratory of the revised self-monitoring schedule. (Section 8.4, Requesting, Receiving, and Analyzing Reports) The self-monitoring report certification form for Telco Foods did not identify all the required parameters listed in the dischargers permit. The Tetra Tech inspection team recommends that the City revise the self-monitoring report certification form for Telco Foods to reflect the pollutants to be monitored during a self-monitoring event, as specified in the industrys discharge permit. (Section 8.4, Requesting, Receiving, and Analyzing Reports) The slug discharge control plan for Telco Foods was submitted to the City as required. The Citys review outline showed that the plan did not meet the minimum requirements. The City is required to ensure that all slug discharge control plans submitted meet the minimum federal requirements. (Section 8.5, Slug Discharge Control Plans) The Tetra Tech inspection team reviewed the slug discharge control plan criteria outline used by the City to determine compliance and found that the minimum federal requirements at 40 CFR 403.8(f)(2)(v) were not met. The inspection team recommends that the City revise the slug discharge control plan criteria outline to specify the minimum federal requirements. (Section 8.5, Slug Discharge Control Plans) The City is not adequately implementing its ERP in instances of reporting noncompliance. The inspection team found no records that Telco Foods has been notifying the City within 24 hours of noticing noncompliance as required by the discharge permit and at 40 CFR 403.12(g)(2). The City is required to escalate enforcement actions, as specified in its ERP, for failure to notify the City within 24 hours of noticing noncompliance with the pretreatment standards. The Tetra Tech inspection team recommends that the City document all phone calls or other forms of noncompliance notification. (Section 9, Enforcement) The file review revealed that the City has not identified several additional instances of reporting noncompliance (as discussed in section 8.4 of this report). Therefore, the City is required to identify all instances of noncompliance and to implement the enforcement actions outlined in its ERP. 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