ࡱ> M bjbj== aWW}qlJ J J J J J J $n 4%4%4%P%T%n Y& )( * * *,H/0lK kJ 0@,@,^002J J * *6j2220J *J *202~ 2=~d8J J ` *& ќ)n 4%0X`$TYl0`2n n J J J J Pretreatment Compliance Audit Summary Report Discharger: City of Riverside Location: 5950 Acorn Street Riverside, California 92504 Contact(s): Dion Castro, Industrial Waste Supervisor Daryl Hartwill, Senior Industrial Waste Inspector Regan Bailey, Senior Industrial Waste Inspector Inspection Date: November 1314, 2003 Inspected By: Najah Amin, Santa Ana Regional Water Quality Control Board Chuck Durham, Tetra Tech, Inc. Byron Ross, Tetra Tech, Inc. Lynn Kurth, Tetra Tech, Inc. Contents TOC \o "1-5" \h \z   HYPERLINK \l "_Toc60458091" 1. Executive Summary  PAGEREF _Toc60458091 \h 1  HYPERLINK \l "_Toc60458092" 2. Introduction  PAGEREF _Toc60458092 \h 1  HYPERLINK \l "_Toc60458093" 2.1 Size of Program  PAGEREF _Toc60458093 \h 2  HYPERLINK \l "_Toc60458094" 2.2 Description of the City of Riverside Water Quality Control Plant  PAGEREF _Toc60458094 \h 3  HYPERLINK \l "_Toc60458095" 3. Pretreatment Program Modifications  PAGEREF _Toc60458095 \h 3  HYPERLINK \l "_Toc60458096" 4. Local Limits  PAGEREF _Toc60458096 \h 3  HYPERLINK \l "_Toc60458097" 5. Nondomestic Discharger Characterization  PAGEREF _Toc60458097 \h 4  HYPERLINK \l "_Toc60458098" 6. Control Mechanisms  PAGEREF _Toc60458098 \h 4  HYPERLINK \l "_Toc60458099" 6.1 Effluent Limits  PAGEREF _Toc60458099 \h 5  HYPERLINK \l "_Toc60458100" 6.2 Self-monitoring, Sampling, Reporting, and Recordkeeping Requirements  PAGEREF _Toc60458100 \h 5  HYPERLINK \l "_Toc60458101" 6.3 Statement of Penalties  PAGEREF _Toc60458101 \h 6  HYPERLINK \l "_Toc60458102" 7. Application of Pretreatment Standards and Requirements  PAGEREF _Toc60458102 \h 6  HYPERLINK \l "_Toc60458103" 8. Compliance Monitoring  PAGEREF _Toc60458103 \h 6  HYPERLINK \l "_Toc60458104" 8.1 Compliance Sampling  PAGEREF _Toc60458104 \h 7  HYPERLINK \l "_Toc60458105" 8.2 Compliance Inspections  PAGEREF _Toc60458105 \h 7  HYPERLINK \l "_Toc60458106" 8.3 Nondomestic Discharger Site Inspections Conducted During the Audit  PAGEREF _Toc60458106 \h 7  HYPERLINK \l "_Toc60458107" 8.4 Slug Discharge Control Plans  PAGEREF _Toc60458107 \h 8  HYPERLINK \l "_Toc60458108" 9. Enforcement  PAGEREF _Toc60458108 \h 9  HYPERLINK \l "_Toc60458109" 10. Data Management  PAGEREF _Toc60458109 \h 9  HYPERLINK \l "_Toc60458110" 11. Pretreatment Program Outreach  PAGEREF _Toc60458110 \h 9  HYPERLINK \l "_Toc60458111" 12. Summary of Findings, Requirements, and Recommendations  PAGEREF _Toc60458111 \h 10  Attachments Attachment A Sewer Use Ordinance Attachment B Enforcement Response Plan Attachment C Industrial User Classification List Attachment D Standard Conditions for Permits Attachment E Local Limit Pollutant Discharge Limitations Attachment F City of Riverside Local Limit Evaluation Attachment G Permitted Industrial User Information Summary Attachment H SIU Information: Luxfer Gas Cylinders Attachment I SIU Information: Cardinal HealthMedical Products & Services Attachment J SIU Information: Triple H Food Processors, Inc. Attachment K SIU Information: Tri-City Linen Supply Attachment L SIU Information: Specialty Brands, Inc. Attachment M Nondomestic Discharger Site Visit Data Sheets Attachment N Water Enforcement National Database (WENDB) Worksheet Attachment O Reportable Noncompliance (RNC) Worksheet 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 Riverside (City) on November 1314, 2003. The last Pretreatment Compliance Inspection (PCI) of the Citys pretreatment program was performed May 2223, 2003. This inspection report describes the primary concerns generated by the PCA. The Citys staff manages a pretreatment program that consists of 63 permitted nondomestic dischargers. Thirteen of these dischargers are classified as significant industrial users (SIUs), and three of the SIUs are categorical industrial users (CIUs). The members of the staff appear to have a good general grasp of the pretreatment requirements, and the inspectors seem to have a thorough knowledge of their respective nondomestic users. The Citys permits were well organized and information was easily accessible. The City has initiated plans to further increase pretreatment staff involvement with public education and pollution prevention awareness programs. The Citys program is in need of improvement in some areas. These areas include use of correct laboratory method (40 CFR Part 136) references for all parameters, inclusion of specific civil penalty language, slug control plan documentation to meet the minimum requirements of 40 CFR Part 403, consistency in identification of sample location in permit with sample location on laboratory reports, and inclusion of monitoring requirements for some sample locations identified in permits. The Citys staff immediately addressed most of the areas identified as deficient during the course of the audit. The City is considered the pretreatment program control authority for the satellite districts. It is recommended that the multijurisdictional agreements be reviewed to ensure that specific roles and responsibilities with respect to implementation of the pretreatment program in the contributing jurisdictions are clearly defined The City should review current control mechanisms to ensure that pretreatment program requirements are met. 2. Introduction The PCA consisted of three parts: an interview with City industrial pretreatment staff, a review of the pretreatment program files, and site visits to various permitted industries. The interview included a discussion with several members of the Citys industrial pretreatment 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 based on the classifications of the nondomestic dischargers. The files of the following dischargers were reviewed during the PCA: Luxfer Gas Cylinders (CIU subject to 40 CFR 467.36) Triple H Food Processors, Inc. (Noncategorical SIU) Cardinal Health-Medical Products & Services (CIU subject to 40 CFR 439.47) Tri-City Linen Supply (Noncategorical SIU) Several permitted dischargers were also inspected as part of this audit. Inspectors from Tetra Tech, Inc., and the Regional Board accompanied the Citys Industrial Waste Inspectors to assess whether inspection procedures were adequate. To ensure a representative cross section of the Citys pretreatment program, the dischargers selected for inspections were based on classification. The facilities of the following dischargers were visited during the PCA: Luxfer Gas Cylinders (CIU subject to 40 CFR 467.36) Specialty Brands, Inc. (Noncategorical SIU) Cardinal Health-Medical Products & Services (CIU subject to 40 CFR 439.47) 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 63 permitted nondomestic dischargers. Thirteen of these dischargers are classified as SIUs as defined at 40 CFR 403.3(t). They include three CIUs subject to federal categorical pretreatment standards. The City has six classifications referenced in the Citys Enforcement Response Plan (ERP). Class I:SIUs and CIUsTotal:13Class II:10,00024,999 gallons per day (gpd)Total:6Class III:19,999 gpd Total:33Class IV:Dry Categorical (Categorical Process with no discharge)Total:11Class V:Temporary (e.g., Special, Groundwater Remediation)Total:0Class VI:Liquid Waste Haulers*Total:26*Class VI receives letter of authorization to discharge septic waste rather than a permit. Three contributing jurisdictions discharge wastewater to the Citys wastewater collection system: Jurupa, Edgemont, and Rubidoux. All jurisdictions have adopted the Citys sewer use ordinance (SUO) and ERP. The Citys pretreatment staff inspects these jurisdictions quarterly. 2.2 Description of the City of Riverside Water Quality Control Plant The Citys Public Works Department owns and operates the Riverside Regional Water Quality Control Plant (RRWQCP), which provides wastewater treatment for the City and three community service districts (Edgemont, Jurupa, and Rubidoux). Influent wastewater flows through barscreens, undergoes a grit removal process, and is then proportionately channeled to two secondary treatment plants. Treatment in the two plants includes primary sedimentation, aeration basins with anoxic zones, and secondary sedimentation basins. Prior to tertiary treatment, flows from the two secondary plants are combined in equalization basins. The tertiary treatment includes alum and/or polymer injection, dual media filtration, chlorination, and dechlorination. The treated wastewater is then discharged to Reach 3 of the Santa Ana River; a portion of the wastewater is directed through constructed wetlands for further nitrogen removal. Solids handling includes dissolved air flotation thickeners, anaerobic digestion, belt press dewatering, and air-drying. The RRWQCP has a design capacity of 40 million gallons per day (MGD). The average daily flow into the plant is 33 MGD. Based on the Citys Permitted Industrial User Information sheets (Attachment G), the approximate total industrial flow is 1.5 MGD (4.5% industrial flow during average RRWQCP flow). 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. The City is considering a reduction in the industrial user sampling and inspection frequency from four per year to two per year. This reduction still meets the 40 CFR 403.8 (f)(2)(v) requirement of one time per year. The planned reduction in sampling and inspection frequency is being considered to help shift resources to focus on pollution prevention, public outreach, and education. Any modification that results in less stringent oversight than established in the approved program is considered a substantial modification. The City is required to submit all substantial modifications to the Regional Board for approval prior to adoption and implementation as specified at 40 CFR 403.18. 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 completed a local limit evaluation in September 1999 (Attachment F). This evaluation considered protection of receiving stream waters, sludge protection, and plant process inhibition. Based on historical sample results, two pollutants, phenol and total toxic organics (TTO), were removed from the proposed local limit list. Biochemical oxygen demand (BOD) was not listed, but reference was made to the use of the chemical oxygen demand (COD) limit rather than BOD. Temporary discharges from groundwater remediation sites or other special industrial users have the potential to discharge volatile organic compounds (VOC) or semivolatile organic compounds (SVOCs). These temporary dischargers can have VOC and SVOC pollutants, such as benzene, toluene, ethylbenzene, and xylene. Currently, the City uses drinking water standards as local limits for these pollutants. In some cases, the maximum acceptable drinking water limit might not be protective of the collection system, wastewater treatment plant, or receiving stream. It is recommended that the City establish technically based limits for these parameters to ensure protection of the POTW. The previously established TTO limit of 1.5 mg/L was not included in the proposed local limits. Furthermore, if the general TTO limit is added back to the local limits, it is recommended that the City identify the specific list of pollutants to be analyzed for compliance with the TTO limit. 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 Citys definition of an SIU is the same as that in 40 CFR 403.3(t). The Citys pretreatment staff identifies potential industrial users from utility connection notices; a plancheck system in which Codes Administration notifies of plan changes; inspectors visual surveys; phone book reviews; and interaction with the Health Department, Fire Department, and Planners/Building Department. Upon identification of facilities that could affect the POTW, industrial waste survey forms are given to potential industrial users, restaurants, auto shops, printers, and car washes. 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 recordkeeping 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 24-hour notification 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. 6.1 Effluent Limits Luxfer Gas Cylinders (Luxfer) permit has cyanide, zinc, and total chromium on the self-monitoring list but no numerical limit. This was brought to the attention of the City pretreatment staff during file review on November 13, 2003. City staff corrected this on November 13, 2003, and a revised permit page was issued to Luxfer on November 14, 2003. . It is required that the City review all nondomestic discharge permits to ensure that limits for all pollutants are included. Categorical limits from 40 CFR 467.36 did not match the limits in the Luxfer permit. The Luxfer categorical mass limits can change based on production variations. It is recommended that the City modify the Luxfer permit by removing specific concentration limits and replacing them with production-based multiplier found in 40 CFR 467.36. The permit for Triple H Food Processors, Inc. (Triple H), issued in March 2002, still contains old local limits. The fact sheet has been modified, but nothing in the file indicates that the permit was modified. Triple H and the City are monitoring for pollutants based on revised local limits. It is recommended that the City modify the permit issued to this facility to include the modified local limits. 6.2 Self-monitoring, Sampling, Reporting, and Recordkeeping Requirements The City laboratory analysis results for COD, total dissolved solids (TDS), hardness, and pH had incorrect method references. This deficiency was brought to the Citys attention on November 13, 2003, during industrial user file reviews. The Citys pretreatment staff investigated the problem on November 13, 2003, and it was determined that the laboratory data software linkage to the final report was the cause of the incorrect method references. The Citys laboratory staff corrected the method reference error on November 14, 2003. It is recommended that the City review laboratory reports and methods to ensure that correct methods are recorded on the laboratory reports. Inconsistencies in sampling point identification were identified during the file review. For example, the Luxfer sample point identification is listed as Bldg. 3 on laboratory reports and the chain-of custody forms have referred to the sampling locations as Bldg. 3 Manhole and Bldg. 3 Sink. The City was notified of this problem on November 13, 2003, and City pretreatment personnel initiated a review of all industrial user sample points listed on the chain-of-custody and the laboratory reports. On November 14, 2003, City staff inserted the permit sample point reference number on the chain-of-custody form for consistent identification. It is recommended that the City review all nondomestic discharger chain-of-custody forms and laboratory report forms to insure consistent sample point identification. The Triple H permit contains a statement in Section B, page 8, that reads if the User chooses to self-monitor, which implies that the SIU has a choice. Section A of the permit mandates that self-monitoring be conducted. It is recommended that the City change the language of the permit to clarify the intent of this statement. The Cardinal Health-Medical Products & Services permit (page 8) states that the industrial user must monitor at Outfall 001 at a specified sampling point. It is recommended that the permit be modified to more clearly identify the sampling point applicable to the outfall. 6.3 Statement of Penalties The Citys Standard Conditions for Permits, Section D.9 (Attachment D) does not list the specific civil penalty maximum amount. It does reference maximum sum provided by law. The requirement of specific penalty amounts is found in 40 CFR 403.8. Therefore, the City is required to modify all nondomestic discharger permits to include a specific civil penalty maximum value. 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 Citys SUO, ERP, and local limits are listed as separate resolutions. The City has legal authority to operate their pretreatment program as required by 40 CFR 403.8(f)(1). The City is considered the pretreatment program control authority for Jurupa, Edgemont, and Rubidoux satellite districts. It is recommended that the multijurisdictional agreements be reviewed to ensure that specific roles and responsibilities with respect to implementation of the pretreatment program in the contributing jurisdictions are clearly defined. 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. The file review and interview indicated that the pretreatment staff conducts investigations of instances of noncompliance and implements enforcement activities 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 currently samples all SIUs four times per year. Reducing the sampling frequency to two times per year is being considered. The goal of the reduced sampling frequency is to allow for more emphasis on pollution prevention and the development of water quality educational programs. 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 inspects all SIUs four times per year. Reducing the inspection frequency to two times per year is being considered. The goal of the reduced inspection frequency is to allow for more emphasis on pollution prevention and the development of water quality educational programs. 8.3 Nondomestic Discharger Site Inspections Conducted During the Audit The audit team, along with City personnel, inspected three of the permitted nondomestic dischargers as part of the audit. The dischargers were selected to represent facilities of varying size and classification. The audit team noted the following during the nondomestic discharger site visits: Luxfer Gas Cylinders This discharger is an aluminum forming company that manufactures extruded aluminum gas cylinders of various sizes. The discharger is a CIU subject to 40 CFR 467.36, Extrusion subcategory, Subpart C. Changes in the process over the past 5 years have caused a significant decrease in wastewater discharge flow. City pretreatment staff delivered an updated local limits sheet, as per audit findings, to the industrial representative during the inspection. Cardinal Health-Medical Products & Services This discharger specializes in the manufacture of injection molded medical components and produces an iodine antimicrobial solution in plastic bottles. This discharger is a CIU subject to 40 CFR Part 439.47, Pharmaceutical Manufacturing, Subpart D, Mixing/Compounding and Formulation Subcategory. There are two designated sample locations for this discharger. One sample location collects categorical and noncategorical wastewater discharges, and the other sample location is a sample wye that collects discharge from the categorical process area only. General housekeeping and condition of process area were excellent. Specialty Brands, Inc. This SIU is a food preparer that produces frozen burritos. Wastewater is generated from food washing, kettle washing, floor washing, and equipment cleaning. The discharger is permitted to discharge up to 122,000 gpd, with current average daily flow at approximately 100,000 gpd. The pretreatment system consists of an upstream grease interceptor, aeration, cationic polymer addition just prior to the primary tank, and primary clarification that includes a grease-skimmer device. The discharger also monitors for pH continuously. At the time of the inspection, the pretreatment system was performing satisfactorily. Chemical storage facilities were adequate. General housekeeping and condition of the process area were fair. 8.4 Slug Discharge Control Plans 40 CFR 403.8(f)(2)(v) requires the City to evaluate each SIU, at least once every 2 years, for the need 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 file review did not show evidence of formal approval of the SIUs slug discharge control plans. Inspection reports indicate that slug discharge control plans were onsite or evaluated, but there was no evidence of approval of plans. The City is required to document formal approval of the SIUs slug discharge control plans to verify that the plans meet the requirements outlined in 40 CFR 403.8(f)(2)(v). 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 City has developed and implemented an ERP. The ERP was approved on July 25, 1995. A copy of the City of Riverside ERP is included in Appendix C. Recently, the City published four SIUs in significant noncompliance in the largest daily newspaper. Also, at the time of the audit, there was an escalation in enforcement activity with Triple H. Triple H is under criminal investigation by the Environmental Protection Agency (EPA) stemming from violations from 20012002. 10. Data Management The Citys industrial user files were well organized and included facility contact information, compliance data, inspection results, self-monitoring data, and permits. Nondomestic user information is stored in hardcopy files and a computer database of industries is maintained. The pretreatment staff located information in a timely and efficient manner. The City asks that requests from the public to review files of industrial users be submitted in writing to the City. Written requests are generally responded to within 7 days. All files are in a secure room, and confidential files are labeled and then separated from regular files. It is recommended that City pretreatment staff evaluate historical data for the wastewater treatment plant influent, effluent, and sludge to document the impact from pollutant loadings. It was noted that these historical data do exist and have been reviewed sporadically, but they are in another section of the Citys Public Works Department. Pretreatment staff should be aware of and closely monitor pollutant trends for the influent, effluent, and sludge to demonstrate pollutant reductions or to identify pollutant loading increases. 11. Pretreatment Program Outreach The City sponsors at least one public awareness and education event per quarter. These events include participation from the pretreatment staff on topics such as fats, oils, and grease control and treatment technologies for storm water and industrial wastewater. Currently, special studies are being conducted for boron, sodium, and TDS. In addition, the pretreatment staff works with the City of Riverside Solid Waste Division and County Household Hazardous Waste Division to help make pollution prevention and reduction more effective. The City is initiating an increase in public awareness and education emphasis. New staff members have been added to better communicate with the public regarding pollution prevention. 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 cited sections of the report. The City is considering modifying the pretreatment program by reducing the sampling and inspection frequency of SIUs from four times per year to two times per year. Any modification that results in less stringent oversight than established in the approved program is considered a substantial modification. The City is required to submit all substantial modifications to the Regional Board for approval prior to adoption and implementation as specified at 40 CFR 403.18. (Section 3, Pretreatment Program Modifications) Currently, the city uses drinking water standards as local limits for groundwater remediation sites or other special nondomestic users that have the potential to discharge VOCs or SVOCs. In some cases, the maximum acceptable drinking water limit might not be protective of the collection system, wastewater treatment plant, or receiving stream. . It is recommended that the City establish technically based limits for these parameters to ensure protection of the POTW. The previously established TTO limit of 1.5 mg/L was not included in the proposed local limits. Furthermore, if the general TTO limit is added back to the local limits, it is recommended that the City identify the specific list of pollutants to be analyzed for compliance with the TTO limit. (Section 4, Local Limits) Luxfers permit has cyanide, zinc, and total chromium on the self-monitoring list but no numerical limit is issued. This was brought to the attention of the City pretreatment staff during file review on November 13, 2003. City staff corrected this on November 13, 2003, and a revised permit page was issued to Luxfer on November 14, 2003. It is required that the City review all nondomestic discharge permits to ensure that limits for all pollutants are included. (Section 6.1, Effluent Limits) Categorical limits from 40 CFR 467.36 did not match the limits in the Luxfer permit. The Luxfer categorical mass limits can change based on production variations. It is recommended that the City modify the Luxfer permit by removing specific concentration limits and replacing them with production-based multiplier found in 40 CFR 467.36. (Section 6.1, Effluent Limits) It is recommended that the City modify the Triple H permit to reference updated local limits. Local limits were modified on December 12, 2002. The permit issued to Triple H in March 2002 still contains old limits. (Section 6.1, Effluent Limits) The Citys laboratory analysis results for COD, TDS, hardness, and pH had incorrect method references. This deficiency was brought to the Citys attention on November 13, 2003, during industrial user file reviews. The Citys pretreatment staff investigated the problem on November 13, 2003 and it was determined that the laboratory data software linkage to the final report was the cause of the incorrect method references. The Citys laboratory staff corrected the method reference error on November 14, 2003. It is recommended that the City review laboratory reports and methods to ensure that correct methods are recorded on the laboratory reports. (Section 6.2, Self-monitoring, Sampling, Reporting, and Recordkeeping Requirements) Inconsistencies in sampling point identification were identified during the file review. It is recommended that the City review all nondomestic discharger chain-of-custody forms and laboratory report forms to insure consistent sample point identification. (Section 6.2, Self-monitoring, Sampling, Reporting, and Recordkeeping Requirements) It is recommended that the City modify the language in the Triple H permit (Section B, page 8) to clarify intent of the statement that reads if the User chooses to self-monitor. Section A of the permit mandates self-monitoring. (Section 6.2, Self-monitoring, Sampling, Reporting, and Recordkeeping Requirements) It is recommended that the Cardinal Health permit (page 8) be modified to more clearly identify the sampling point applicable to the outfall. (Section 6.2, Self-monitoring, Sampling, Reporting, and Recordkeeping Requirements) The Citys Standard Conditions for Permits, Section D.9 does not list the specific civil penalty maximum amount. It does reference maximum sum provided by law. EPA Region 9 interprets 40 CFR 403.8 as requiring specific penalty amounts. Therefore, the City is required to modify all nondomestic discharger permits to include a specific civil penalty maximum value. (Section 6.3, Statement of Penalties) It is recommended that the multijurisdictional agreements be reviewed to ensure that specific roles and responsibilities with respect to implementation of the pretreatment program in the contributing jurisdictions are clearly defined. (Section 7, Application of Pretreatment Standards and Requirements) The City is required to document formal approval of the SIUs slug discharge control plans to verify that the plans meet the requirements outlined in 40 CFR 403.8(f)(2)(v). (Section 8.4, Slug Discharge Control Plans) Draft PCA Summary Report  PCA Summary Report PAGE ii City of Riverside PAGE ii City of Riverside .4ARTU^.>Ub ;<=>@ARSTmnopqrstuѻѹԻќѻѹj>*B*Uphj{U jU5CJ\aJj>*B*Uph0J j0JU jU B*ph\aJ WZF5\5CJ OJQJ\^J:./01234TUr-.TUp^p p^p`$a$sS h L  w Y ] ;=Kl  T@ "(  @ "( 4567;<|}~ܳܝjSUj>*B*Uphj]Uj>*B*UphjgU0JaJj>*B*Uph0J5CJ\aJ j0JU jUjqU: !"#%&234MNOPQRSTUpqrsuv         1 2 ݸݢj5Uj>*B*Uphj?Uj>*B*UphjIU jUj>*B*Uph0J5CJ\aJ j0JU<2 3 4 7 8 G H I b c d e f g h i j       + , - F G H I J K L M N i j k l n ѭїj >*B*Uphj Uj >*B*Uphj! Uj>*B*Uph0Jj+U jU0JaJ j0JUj>*B*Uph9n o        ! < = > ? B C V W X q r s t u v w x y ݴݴjt >*B*Uphj U0JaJj~ >*B*Uphj Uj >*B*Uph j0JUj U jU0J5CJ\aJ; 8 9 : S T U V W X Y Z [ v w x y | }      jU5CJ\aJjV>*B*UphjUj`>*B*UphjU0JaJjj>*B*Uph0J j0JU jUj U:  & ' ( ) , - < = > W X Y Z [ \ ] ^ _ z { | } 45689:;<=>ݸݢCJaJ jUjUj8>*B*UphjUjB>*B*UphjU jUjL>*B*Uph0J5CJ\aJ j0JU;>KrtuR"!#!#!$$$%$:%>%**H.I.^6_6::]>^>;CZf[h[i\k\\\\e]g]1_3____bb]e^ese j B*CJph 6CJaJ]>*56CJaJaJaJ6 B*phCJaJCJ5B*CJ\phK*`U<ru!"q T  T@ "(wCEƀkFCEƀkF[QRysqq !CEƀkFCEƀkFRq*(F & FEƀkFF & FEƀkFF & FEƀkF"!#!7!8!""""""""jv$$Ifl\lt"X8"2+2 s4 la $$Ifa$$If  !$If """"""""##yv$$Ifl\lt"X8"2+2 s4 la $$Ifa$$If # ##K#R#U#V#_########4||||| $$Ifa$$Ift$$Ifl\lt"X8"2+2 s4 la###"$#$$$%$p|A97 !q;$$Iflt"""2+2 s4 la$Ift$$Ifl\lt"X8"2+2 s4 la $$Ifa$%$:%;%<%=%>%%%))****++I.Y.Z.0022^6_66688:::::e;f;;;mF & FEƀkFF & FEƀkF;;<'<q*F & FEƀkFF & FEƀkFF & FEƀkF'<L<<<q*F & FEƀkFF & FEƀkFF & FEƀkF<<<=q*F & F EƀkF*-F & F EƀkF)-F & F EƀkF(-=J=K=]>^>r>s>Q@R@AA;CZg[h[]F & F$EƀkF^ !h^hF & F$EƀkFh[j\k\\\\\\oiic]^ !h^hF & F$EƀkFF & F$EƀkF\f]g]2_3_kiF & F$EƀkFh^hF & F$EƀkF3_____``bbbbbccdd]e^ereseh^hF & F$EƀkF seg j j,j-jGllm;m-pBsCs2u3uoF & F%EƀkF.F & F%EƀkF.3uvvwwoF & F%EƀkF.F & F%EƀkF.w{z|z{{oF & F%EƀkF.F & F%EƀkF.{ } }}}oF & F%EƀkF .F & F%EƀkF.}ga !F & F%EƀkF . ^`F & F%EƀkF .ÁāЁh]h&`#$ $a$h^hF & F%EƀkF . CJOJQJ. 00&P1h/R / =!"#$%/0&P1hP/R / =!"#$%{DyK  _Toc60458091{DyK  _Toc60458091{DyK  _Toc60458092{DyK  _Toc60458092{DyK  _Toc60458093{DyK  _Toc60458093{DyK  _Toc60458094{DyK  _Toc60458094{DyK  _Toc60458095{DyK  _Toc60458095{DyK  _Toc60458096{DyK  _Toc60458096{DyK  _Toc60458097{DyK  _Toc60458097{DyK  _Toc60458098{DyK  _Toc60458098{DyK  _Toc60458099{DyK  _Toc60458099{DyK  _Toc60458100{DyK  _Toc60458100{DyK  _Toc60458101{DyK  _Toc60458101{DyK  _Toc60458102{DyK  _Toc60458102{DyK  _Toc60458103{DyK  _Toc60458103{DyK  _Toc60458104{DyK  _Toc60458104{DyK  _Toc60458105{DyK  _Toc60458105{DyK  _Toc60458106{DyK  _Toc60458106{DyK  _Toc60458107{DyK  _Toc60458107{DyK  _Toc60458108{DyK  _Toc60458108{DyK  _Toc60458109{DyK  _Toc60458109{DyK  _Toc60458110{DyK  _Toc60458110{DyK  _Toc60458111{DyK  _Toc60458111+ i8@8 NormalCJ_HaJmH sH tH R@R Heading 1$<@&5CJKH OJQJ\^JaJ T@T Heading 2$<@& 56CJOJQJ\]^JaJNN Heading 3$<@&5CJOJQJ\^JaJBB Heading 4$<@&5CJ\aJFF Heading 5 <@&56CJ\]aJ@@ Heading 6 <@&5CJ\aJ22 Heading 7 <@&88 Heading 8 <@&6]F F Heading 9 <@&CJOJQJ^JaJ<A@< Default Paragraph Font:>@: Title$a$5CJ OJQJ\^JVOV Body textx7$8$H$!B*CJ_HaJmH phsH tH 0O0 bullet  & FPCJR"R bullet 2nd level & F 88^8CJF!2F bullet 2nd level - lastx^@^TOC 1'$ h#! Ldh`La$5CJ\aJmHnHuF@FTOC 2 ! #dh^# mHnHu&& TOC 3 ^&& TOC 4 ^&& TOC 5 ^&& TOC 6 ^&& TOC 7 ^&& TOC 8 ^&& TOC 9 ^.U@. Hyperlink >*B*ph, @, Footer  !&)@& Page Number,@, Header !66 bullet last ! & FxDB"D Body Text"B*CJOJQJ^JaJph@2@  Balloon Text#CJOJQJ^JaJ@B@ numbered list $ & F B*ph4PR4 Body Text 2% B*phf.Qb. Body Text 3&CJ:'@q: Comment ReferenceCJaJ44  Comment Text(CJaJ>V@> FollowedHyperlink >*B* phDC@D Body Text Indent*0^`0u ~0./01234TUr-.TUsShLwY ] ; = K l * `  U < r u !"q[QR"#78 KRUV_" # $ % :!;!!!!%%&&&&''I*Y*Z*,,..^2_222446666e7f77778'8L888889J9K9]:^:r:s:Q<R<==;?VgWhWjXkXXXXXXfYgY2[3[[[[[\\^^^^^__``]a^arasac f f,f-fGhhi;i!0>!0>!0>!0>!00&0&0&0&00I*0I*0I*0I*0I*0I*0I*00_20_20_20_20_20060606 06 06 06 06 06 06 06 06 06 06 06 06060606060^:0^:0^:0^:0^:0^:0^:060 jGKLMNOPQhoR"##%$:;'<<=JUFXYh[\3_se-p3uw{}HJRSTUVWXYZ[\]^_`abcdefgijklmnI=Snpqs6}"3NPQSr3Hcefh,GIJLk>Wrtuw9TVWYx   ( = X Z [ ] |  5 8 9 ; ~ X%X%X%X%X%X%X%X%X%X%X%X%X%X%X%X%X%X%X%X%X%̕18;PWZs!!@  @ 0(  B S  ?J2(  NB  S DjJNB  S DjJ$NB  S D8c)\sh!hu!u!u _Hlt60039126 _Toc60458091 _Toc60458092 _Toc60458093 _Toc60458094 _Toc60458095 _Toc60458096 _Toc60458097 _Toc60458098 _Toc60458099 _Toc60458100 _Toc60458101 _Toc60458102 _Toc60458103 _Toc60458104 _Toc60458105 _Toc44839688 _Toc60458106 _Toc37758686 _Toc60458107 _Toc60458108 _Toc27815624 _Toc60458109 _Toc27815625 _Toc60458110 _Toc60458111u u #>!&I*_26^:J'_6ufihr~AJj"Vpn nEZyE&2}'F"<cLgfpVR?S~$7,TpwTsSdVQ:XX2~I8^x?ELfugRZ42pfZ|ulp AxdIx`5~ h^`o(.h^`.hpLp^p`L.h@ @ ^@ `.h^`.hL^`L.h^`.h^`.hPLP^P`L.h^`.h^`.hpLp^p`L.h@ @ ^@ `.h^`.hL^`L.h^`.h^`.hPLP^P`L.h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(z^`zo(0^`0o(.0^`0o(..88^8`o(... `^``o( .... `^``o( ..... ^`o( ...... ^`o(....... pp^p`o(........h88^8`o(.h^`.h L ^ `L.h  ^ `.hxx^x`.hHLH^H`L.h^`.h^`.hL^`L.h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(^`o(.^`.pLp^p`L.@ @ ^@ `.^`.L^`L.^`.^`.PLP^P`L.h^`o(.h^`.hpLp^p`L.h@ @ ^@ `.h^`.hL^`L.h^`.h^`.hPLP^P`L.h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h^`.h^`.hpLp^p`L.h@ @ ^@ `.h^`.hL^`L.h^`.h^`.hPLP^P`L.(h88^8`OJPJQJ^Jo(-h ^`OJQJo(oh   ^ `OJQJo(h   ^ `OJQJo(h xx^x`OJQJo(oh HH^H`OJQJo(h ^`OJQJo(h ^`OJQJo(oh ^`OJQJo(z^`zo(0^`0o(.0^`0o(..88^8`o(... `^``o( .... `^``o( ..... ^`o( ...... ^`o(....... pp^p`o(........h^`.h^`.hpLp^p`L.h@ @ ^@ `.h^`.hL^`L.h^`.h^`.hPLP^P`L.^`o(.^`.L^`L.  ^ `.\ \ ^\ `.,L,^,`L.^`.^`.L^`L.h^`o(.h^`.hpLp^p`L.h@ @ ^@ `.h^`.hL^`L.h^`.h^`.hPLP^P`L.h ^`OJQJo(h^`QJo(h pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo( ^` o( ^` o(.0^`0o(..0^`0o(... 88^8`o( .... 88^8`o( ..... `^``o( ...... `^``o(....... ^`o(........ ^`o(0^`0o(.0^`0o(..88^8`o(... `^``o( .... `^``o( ..... ^`o( ...... ^`o(....... pp^p`o(........0^`0o(0^`0o(.0^`0o(..0^`0o(... 88^8`o( .... 88^8`o( ..... `^``o( ...... `^``o(....... ^`o(........0^`0o(0^`0o(.0^`0o(..88^8`o(... `^``o( .... `^``o( ..... ^`o( ...... ^`o(....... pp^p`o(........  ^ `o(^`o(.  ^ `o(..  ^ `o(... 88^8`o( .... `^``o( ..... `^``o( ...... ^`o(....... ^`o(........h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(z^`zo(0^`0o(.0^`0o(..88^8`o(... `^``o( .... `^``o( ..... ^`o( ...... ^`o(....... pp^p`o(........808^8`0o(.^`.pLp^p`L.@ @ ^@ `.^`.L^`L.^`.^`.PLP^P`L.h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(^`o(.^`.pLp^p`L.@ @ ^@ `.^`.L^`L.^`.^`.PLP^P`L.h^`.h^`o(.hpLp^p`L.h@ @ ^@ `.h^`.hL^`L.h^`.h^`.hPLP^P`L.h^`o(.h^`.hpLp^p`L.h@ @ ^@ `.h^`.hL^`L.h^`.h^`.hPLP^P`L.h^`.h^`.hpLp^p`L.h@ @ ^@ `.h^`.hL^`L.h^`.h^`.hPLP^P`L.h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(z^`zo(0^`0o(.0^`0o(..88^8`o(... `^``o( .... `^``o( ..... ^`o( ...... ^`o(....... pp^p`o(........h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo( z^`zo(0^`0o(.0^`0o(..88^8`o(... `^``o( .... `^``o( ..... ^`o( ...... ^`o(....... pp^p`o(........ ^` o( ^` o(. 0^`0CJaJo(..0^`0o(... 88^8`o( .... 88^8`o( ..... `^``o( ...... `^``o(....... ^`o(........z^`zo(()^`.pLp^p`L.@ @ ^@ `.^`.L^`L.^`.^`.PLP^P`L.^`5o(.^`.pLp^p`L.@ @ ^@ `.^`.L^`L.^`.^`.PLP^P`L. 0^`0o(0^`0o(.0^`0o(..0^`0o(... 88^8`o( .... 88^8`o( ..... `^``o( ...... `^``o(....... ^`o(........h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h^`o(.h^`.hpLp^p`L.h@ @ ^@ `.h^`.hL^`L.h^`.h^`.hPLP^P`L.)>nEpVRyEIxnW(22}'F*(I8^CEufi~-,& Ax@U}SdVOPwTSn *AJ$7,T5~p&sC?cLV6XX6$*?ELfBJ'_Z|u2pKD2ugmQj*))d:-                          d:-                          d:-                          Yl                 `        d:-         t                ̀n                 ?H                           ϸ       d:-        *o                          4\f        V                 d:-         KRUV_" # }}~@~@@UnknownTetra Tech Inc.,leeihJacqueline JohnsonG:Times New Roman5Symbol3& :ArialG" HelveticaArialA& Arial Narrow5& :Tahoma?5 :Courier New;Wingdings"hVҁ&ҁ&*g5i6!r0d({| 3QH)Pretreatment Compliance Inspection ReportleeihDells Oh+'0 (4 P \ h t*Pretreatment Compliance Inspection ReportrdretleeihateeieeiNormaltDellst4llMicrosoft Word 9.0a@^в@$9)@q> @.)*g ՜.+,D՜.+,` hp  Tetra Tech, Inc5( *Pretreatment Compliance Inspection Report TitleH _PID_HLINKS_AdHocReviewCycleID_EmailSubject _AuthorEmail_AuthorEmailDisplayName_PreviousAdHocReviewCycleIDA~;z _Toc60458111;t _Toc60458110:n _Toc60458109:h _Toc60458108:b _Toc60458107:\ _Toc60458106:V _Toc60458105:P _Toc60458104:J _Toc60458103:D _Toc60458102:> _Toc60458101:8 _Toc6045810032 _Toc604580993, _Toc604580983& _Toc604580973  _Toc604580963 _Toc604580953 _Toc604580943 _Toc604580933 _Toc604580923 _Toc60458091'Riverside correctedMMSLLC@comcast.netMMSLLC@comcast.net  !"#$%&'()*+,-./0123456789:;<=>?@ABCDEFGHIJKLMNOPQRSTUVWXYZ[\]^_`abcdefghijklmnoprstuvwxyz{}~Root Entry Fۜ)Data q.1Table|WordDocumentaSummaryInformation(DocumentSummaryInformation8CompObjjObjectPoolۜ)ۜ)  FMicrosoft Word Document MSWordDocWord.Document.89q