ࡱ> % pbjbj%% aGGVkpOlV V V V f & $ hhhPD  J#(r#r##&()lhjjjjjj$# CV *%%^**5V V ##6*555*V #V #h5*h5 5<@Ч`V V D# PA?X& h,Z0\D$ͱ< Ӷ.ӶD5 V V V V Pretreatment Compliance Inspection Summary Report Discharger: City of Riverside Location: 5950 Acorn Street Riverside, California 92504 Contacts: Dion Castro, Industrial Waste Supervisor Daryl Hartwill, Senior Industrial Waste Inspector Regan Bailey, Senior Industrial Waste Inspector Tim King, Industrial Waste Inspector II Nicole Greene, Industrial Waste Inspector I Inspection Dates: November 910, 2004 Inspected by: Najah Amin, Santa Ana Regional Water Quality Control Board Danny OConnell, Tetra Tech, Inc. Michelle Ittes, Tetra Tech, Inc. Contents  TOC \o "1-5" \h \z  HYPERLINK \l "_Toc96220817" 1. Executive Summary  PAGEREF _Toc96220817 \h 1  HYPERLINK \l "_Toc96220818" 2. Introduction  PAGEREF _Toc96220818 \h 1  HYPERLINK \l "_Toc96220819" 2.1 Size of Program  PAGEREF _Toc96220819 \h 2  HYPERLINK \l "_Toc96220820" 2.2 Description of the Water Quality Control Plant  PAGEREF _Toc96220820 \h 3  HYPERLINK \l "_Toc96220821" 3. Pretreatment Program Modifications  PAGEREF _Toc96220821 \h 3  HYPERLINK \l "_Toc96220822" 4. Local Limits  PAGEREF _Toc96220822 \h 4  HYPERLINK \l "_Toc96220823" 5. Nondomestic Discharger Characterization  PAGEREF _Toc96220823 \h 4  HYPERLINK \l "_Toc96220824" 6. Control Mechanisms  PAGEREF _Toc96220824 \h 5  HYPERLINK \l "_Toc96220825" 7. Application of Pretreatment Standards and Requirements  PAGEREF _Toc96220825 \h 5  HYPERLINK \l "_Toc96220826" 8. Compliance Monitoring  PAGEREF _Toc96220826 \h 6  HYPERLINK \l "_Toc96220827" 8.1 Compliance Sampling  PAGEREF _Toc96220827 \h 6  HYPERLINK \l "_Toc96220828" 8.2 Compliance Inspections  PAGEREF _Toc96220828 \h 6  HYPERLINK \l "_Toc96220829" 8.3 Nondomestic Discharger Site Inspections Conducted During the PCI  PAGEREF _Toc96220829 \h 7  HYPERLINK \l "_Toc96220830" 8.4 Slug Discharge Control Plans  PAGEREF _Toc96220830 \h 7  HYPERLINK \l "_Toc96220831" 9. Enforcement  PAGEREF _Toc96220831 \h 8  HYPERLINK \l "_Toc96220832" 10. Data Management  PAGEREF _Toc96220832 \h 8  HYPERLINK \l "_Toc96220833" 11. Pretreatment Program Outreach  PAGEREF _Toc96220833 \h 8  HYPERLINK \l "_Toc96220834" 12. Summary of Findings, Requirements, and Recommendations  PAGEREF _Toc96220834 \h 9  Attachments Attachment A Citys Response to 2003 Pretreatment Compliance Audit Attachment B Corrected Luxfer Gas Cylinders Permit Attachment C Sewer Use Ordinance Attachment D Enforcement Response Plan Attachment E Industrial User Classification List Attachment F Standard Conditions for Permits Attachment G Permitted Industrial User Information Summary Attachment H SIU Information: Pepsi Bottling Group, Permit #00152 Attachment I SIU Information: Prudential Overall Supply, Permit #00055 Attachment J SIU Information: Ralphs Grocery Company, Permit #00195 Attachment K Nondomestic Discharger Site Visit Data Sheets Attachment L Public Education and Outreach Information on Web Site Attachment M Automated Data Management System Information Attachment N Water Enforcement National Database and Reportable Noncompliance Worksheet Attachment O Significant Nonompliance Tracking and Publication Documentation 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 Riverside (City) on November 910, 2004. The last Pretreatment Compliance Audit (PCA) of the Citys pretreatment program was performed on November 1314, 2003. This inspection report describes the programs activities and primary concerns generated by the recent PCI. The Citys Environmental Compliance Section (ECS) manages the industrial pretreatment program. The program consists of 71 permitted nondomestic dischargers. Twelve of these dischargers are classified as significant industrial users (SIUs), and two of the SIUs are categorical industrial users (CIUs) subject to federal pretreatment requirements. The members of the ECS 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 field staff is supported by a multilevel management team structure; the team has specialized expertise in field operations and regulation application to nondomestic dischargers. The Citys permits were found to be well organized and information was easily accessible. The City has continued its use of pretreatment staff as a vital component of the public education and pollution prevention awareness programs. The 2003 PCA of the Citys pretreatment program identified the need for program improvements in some areas. These areas included use of correct laboratory methods as defined in Title 40 of the Code of Federal Regulations (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 403.8(g)(2), consistency in identification of sampling locations in permits with sampling locations in laboratory reports, and inclusion of monitoring requirements for some sampling locations identified in permits. As stated in last years PCA report, the Citys staff immediately addressed most of the areas identified as deficient during the course of the audit. These corrective actions were verified as part of this inspection. The Citys summary of the situations identified as needing improvement as well as the corrective actions implemented can be found in Attachment A of this report. The Citys program is finalizing a list of proposed program modifications. 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. In addition, during the inspection of two industrial users a couple of areas needing improvement were identified. A summary of recommendations is presented at the end of this report. 2. Introduction The PCI consisted of three parts: an interview with City industrial pretreatment staff, a review of the pretreatment program files, and site visits to two 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, the operation of the Citys automated data management system, 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 PCI: Pepsi Bottling Group (Noncategorical SIU) Prudential Overall Supply (Noncategorical SIU) Ralphs Grocery Company (Noncategorical SIU) An inspector from Tetra Tech, Inc., and the Regional Boards representative accompanied the Citys ECS 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 chosen based on classification and possible impact on the wastewater treatment facility. The facilities of the following dischargers were visited during the PCI: Pepsi Bottling Group (Noncategorical SIU) Ralphs Grocery Company (Noncategorical SIU) This report summarizes the overall findings of the file reviews and inspections. 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 71 permitted nondomestic dischargers. Twelve of these dischargers are classified as SIUs as defined at 40 CFR 403.3(t). They include two CIUs subject to federal categorical pretreatment standards. The City has six classifications referenced in its enforcement response plan (ERP). Class I:SIUs and CIUsTotal:12Class 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:10Class V:Temporary (e.g., Special, Groundwater Remediation)Total:0Class VI:Liquid Waste Haulers*Total:20*Class VI receives a 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 three jurisdictions have adopted the Citys sewer use ordinance and ERP. The Citys pretreatment staff inspects these jurisdictions quarterly. The City is considered the pretreatment program control authority for three satellite districts: Edgemont Community Service District, Jurupa Community Service District, and Rubidoux Community Service District. The 2003 PCA 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 ECS team has reviewed the multijurisdictional agreements with respect to technical and legal needs with the assistance of legal counsel. The documents give specific roles and responsibilities to the ECS and the service districts. The City reported that its staff have met with the satellite districts quarterly to review agreement requirements and provide assistance as needed. 2.2 Description of the 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) and serves a population of approximately 500,000. Influent wastewater flows through bar screens, 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. Construction is under way to expand the capacity to 60 MGD. Based on the Citys permitted industrial user population (Attachment G), the approximate total industrial flow is 1.9 MGD (5.8 percent 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 in the drafting stages of modifying the programs operational protocol and standard operating procedures (SOPs). The ECS 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 annual compliance inspection and compliance monitoring. The planned reduction in sampling and inspection frequency is being considered to help shift resources to focus on pollution prevention, public outreach and education, as well as the implementation and management of the Citys sanitary sewer overflow and storm water programs. This modification, which 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. This evaluation considered protection of receiving stream waters, sludge protection, and plant process inhibition. Based on historical sampling results, two pollutants, phenol and total toxic organics (TTOs), 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. The City is scheduled to start a reevaluation of the local limits in January 2005. The reevaluation will include an evaluation of historical POTW and industrial analyses as well as a new round of domestic monitoring. Temporary discharges from groundwater remediation sites or other special industrial users have the potential to discharge volatile organic compounds (VOCs) or semivolatile organic compounds (SVOCs). These temporary dischargers are required to document compliance with applicable surface and groundwater quality standards before the City issues a permit for their discharges. The ECS team states that exceptions for individual constituents may be approved if the applicant is willing to fund or perform an approved monitoring and modeling program. The program must demonstrate that there will be no significant effect on the POTWs ability to maintain compliance with all applicable regulations. 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 nondomestic dischargers that might be subject to the local pretreatment program. These procedures must also include proper categorization of all SIUs as defined at 40 CFR 403.3(t). The Citys definition of an SIU is the same as that in 40 CFR 403.3(t). The Citys procedures for identifying nondomestic dischargers were found to be adequate. The Citys pretreatment staff identifies potential nondomestic dischargers from utility connection notices; a plan check system in which the Codes Administration notifies of plan changes; inspectors visual surveys; phone book reviews; interaction with the Health Department, Fire Department, and Planners/Building Department; and cross reference evaluations with the local Air Quality Management District. Upon identification of facilities that could affect the POTW, the City provides industrial waste survey forms to potential industrial users, restaurants, auto shops, veterinarians, photo processors, 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. Areas of concern identified in the 2003 PCA were confirmed corrected during this inspection. 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 2003 PCA found that the categorical limits in 40 CFR 467.36 did not match the limits in the Luxfer permit. The 2003 PCA recommended that the City modify the Luxfer permit by removing specific concentration limits and replacing them with the production-based multiplier found in 40 CFR 467.36. The City has complied with the recommendation and has modified the Luxfer permit. 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 investigates 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 a year. The City is finalizing the draft of proposed modifications to its program. In the proposal, a reduction of the sampling frequency to two times a 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. Reduction of compliance sampling is considered a significant change to the Citys pretreatment program as defined in 40 CFR 403.18; therefore, the City is required to notify the Regional Board before implementing the program change. 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 a year. The City is finalizing the draft of proposed modifications to its program. In the proposal, a reduction of the inspection frequency to two times a 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. Reduction of compliance inspections is considered a significant change to the Citys pretreatment program as defined in 40 CFR 403.18; therefore, the City is required to notify the Regional Board before implementing the program change. 8.3 Nondomestic Discharger Site Inspections Conducted During the PCI A member of the Tetra Tech inspection team, the Regional Board representative, and members of the ECS field and management staff 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 inspection team noted the following during the nondomestic discharger site visits: Pepsi Bottling Group. The dischargers operations include preparing and bottling Pepsi soft drinks, Tropicana juices, Brisk iced tea, and Aquafina water. Raw ingredients are batched to produce syrups for soft drink beverages. Juices and tea are blended from concentrates. The process area consists of several soft drink, juice, tea, and water lines. The production room was found to be clean and organized. Minor deficiencies, however, were found during the inspection. The significant material storage area contained a floor drain, which was not closed off at the time of the inspection. The inspector from the City of Riverside required that the drain be blocked off by the end of the day. Even though the area was indoors, there was no secondary containment to prevent a spill or to prevent chemicals from coming in contact with one another. A pH reading was taken at the time of the inspection and was found to be in compliance with local limits. No other deficiencies were found during the inspection. Ralphs Grocery Company. The dischargers operations include processing milk, purified drinking and spring water, orange juice, and fruit punch; ice production; and packaging. The facility also produces its own bottles. Milk is delivered by truck to an off-loading area. This area is equipped with a secondary containment catch basin to capture a leak or spill from the off-loading process. In addition, this basin is equipped with an alarm and pump diversion to be activated in the event of a spill. During the inspection, however, the diversion device was inoperable. Tetra Tech recommends that the City revisit the facility to ensure that this pump diversion system is in working order. The facility also has a Blow Molding Room. Plastic bags are blown and heat-molded into milk bottles. The bottles are then filled with milk and other juices, labeled, and shipped to customers. A pH reading was taken at the time of the inspection and was found to be in compliance with local limits. No other deficiencies were found during the inspection. 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)]. Based on the findings of the 2003 PCA, the ECS created and implemented a new slug load control plan (SLCP) form. A review of the new SLCP found that it meets the requirements of 40 CFR 403.8(f)(2)(v). The City sent the forms to all Class I facilities for completion in March 2004. All Class I facilities now have an SLCP based on ECSs new form. 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, which was approved on July 25, 1995. A copy of the City of Riverside ERP is attached to this report as Attachment D. The ECS is working on a draft document that may propose some modifications to the ERP. The ECS is aware that any proposed modifications to the ERP will have to be approved by the Regional Board. The City published four SIUs in significant noncompliance in the The Press-Enterprise (the largest local daily newspaper) on February 25, 2004 (Attachment O). The ECS team maintains a tracking document showing facilities meeting the definition of significant noncompliance. At the time of the inspection it appeared that five facilities have qualified for publication of significant noncompliance based on their compliance activities during the first three quarters of 2004. 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 hard-copy files, and a computer database of industries is maintained. The ECS data management system is called the Pretreatment Database Management System (PDMS). The PDMS is very user friendly and enables the pretreatment staff to locate information in a timely and efficient manner. The PDMS not only manages the traditional pretreatment activities, but also is designed to manage sanitary sewer overflow and storm water activities. The system also tracks ECS staff time versus activities to better manage activities and resources. A summary of some of the systems capabilities can be found in Attachment M. 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. 11. Pretreatment Program Outreach The City sponsors public awareness and education throughout the year. These events include participation by the pretreatment staff on topics such as fat, oil, and grease control and treatment technologies for storm water and industrial wastewater. In addition, the City has implemented a quick dial number, 311, which connects people to an operator trained in environmental issues. The pretreatment staff also works closely with the City of Riverside Solid Waste Division and County Household Hazardous Waste Division to help make pollution prevention and reduction more effective. The Citys Web site has been designed to increase public awareness and education emphasis on environmental issues and concerns. The Web site summarizes the sewer system and services, responds to frequently asked questions, describes the process units used in the treatment of wastewater, and explains the Citys Clean Up Riversides Environment (C.U.R.E.) Program. A general summary of the Web sites various pages can be found in Attachment L. 12. 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 considering modifying the pretreatment program in a various ways. An example is the proposed reduction in the frequency of sampling and inspecting SIUs from four times a year to two times a year. This modification, which 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) It is recommended that the ECS conduct a follow-up inspection to confirm that the Pepsi Bottling Company has sealed the floor drain located in the significant material storage area. (Section 8.3, Nondomestic Site Inspections Conducted During the PCI) It is recommended that the ECS conduct a follow-up inspection to confirm that the Ralphs Grocery Companys secondary containment alarm and pump diversion system is operational and maintained as needed. 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