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This document will describe the enforcement procedures that are used in controlling industrial discharges to <br />the South Bend Publicly Owned Treatment Works. <br />I. Management Plan <br />The pretreatment program for the City of South Bend is administered by the Division of Environmental <br />Services. The responsibilities of the pretreatment program are: <br />l . Collect and verify industrial discharge data through laboratory analyses. <br />2. Make recommendations to the Board of Public Works concerning the issuance of discharge <br />permits. <br />3. Review user discharge monitoring reports. <br />4. Determine the status of user compliance with federal, state, and local regulations. <br />5. Write federal, state, and local mandated pretreatment reports. <br />6. Make recommendations for enforcement actions. <br />Enforcement procedures such as letters of violation, administrative fines, and administrative orders are issued <br />by a Pretreatment Coordinator. Pretreatment Coordinators recommend more serious enforcement responses <br />to the Director of Utilities. Severe violations are reported to the Board of Public Works with <br />recommendations from the Director of Utilities. <br />The following information describes in more detail the management procedures which are used in <br />enforcement of the program. <br />A. Permit Application and Classification <br />Lists of Industrial Users (IUs) are evaluated based on operations performed, water usage and discharge, and <br />chemical inventory, among other factors. Industries identified as belonging to one of the following groups <br />are issued industrial wastewater discharge permits, and categorized as either an Industrial User, or a <br />Significant Industrial User. <br />LIUs subject to federal categorical standards — SIU <br />2.IUs that have process wastewater discharge exceeding 25,000 gallons per day — SIU <br />3.IUs that contribute process wastewater discharge exceeding 5% of the POTW's dry weather <br />hydraulic or organic loading capacity.- SIU <br />4.IUs that have a reasonable potential to adversely affect POTW workers, the POTW itself, and the <br />receiving stream. — SIU <br />5.IUs that have non -significant waste water discharge streams may or may not be issued an industrial <br />wastewater discharge permit. — IUISIU <br />B. Permitting <br />The pretreatment staff assesses the information supplied by a user in its permit application. Discharge <br />parameters to be monitored are set based on application information and local requirements, and limits are <br />set in accordance with local, state, and federal regulations. The industrial wastewater discharge permit is <br />issued by the South Bend Board of Public Works. <br />C. Monitoring <br />Monitoring consists primarily of the following items: <br />St. Joseph Energy Center - Water Treatment Facility Industrial Wastewater Discharge Pen nit — <br />Attaclu7ient 2 <br />