Industrial Wastewater Discharge Permit - Tri-Pac, Inc.

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Tri-Pac Inc. Industrial Wastewater Discharge Permit page 29 of 36 Monitoring consists primarily of the following items: 1. Periodic Compliance Reports submitted to the City of South Bend pretreatment staff as described in each permitted user’s discharge permit. 2. Control Authority (City of South Bend) monitoring including site inspections, and sample collection and analysis. Monitoring events will be conducted both with and without announcement. 3. Compliance report submitted to the City of South Bend pretreatment staff as described in each permitted user’s discharge permit. 4. Other information and reports that convey compliance status which the City of South Bend pretreatment staff may request. D. Field Inspection and Analysis The City of South Bend pretreatment staff collect wastewater discharge samples and inspect industries as required to determine compliance, and to obtain verification of self monitoring data. E. Compliance Decisions and Enforcement Industries found to be out of compliance with federal state, or local requirements are subject to the conditions found in Chapter 17 of the South Bend Municipal Code, described in this Enforcement Response Plan. Informal enforcement actions, letters of violation, administrative fines, and administrative orders are conducted by a Pretreatment Coordinator or by the Director of Environmental Services, depending on the severity of the noncompliance. Enforcement actions which require legal action, criminal investigation, sewer ban, or other penalties may be made by the Board of Public Works upon the recommendation of the Director of Environmental Services. II. Enforcement Response Violations and discrepancies that have been identified are evaluated by the City of South Bend pretreatment staff as to the type of enforcement response necessary. In order to ensure equitable treatment of violators and provide a stronger basis for selection of appropriate responses to violations, the following Enforcement Response Plan should normally be followed. However, certain circumstances or types of violations may require responses that deviate from this plan. The Enforcement Response Plan indicates the type of noncompliance, the circumstances which might vary the type of response and the range of responses for that particular category of noncompliance. The Enforcement Response Plan has been developed with the intention of serving the following purposes. 1. It recommends enforcement responses that are appropriate in relation to the nature and severity of the violation and the overall degree of noncompliance. 2. It provides a guide to encourage a uniform application of enforcement responses to comparable levels in types of violations, and it can be used as a mechanism to review the appropriateness of the response. The Enforcement Response Plan groups various types of violations into the following four categories: 1. Violations of sampling, monitoring, and reporting