HomeMy WebLinkAboutIndustrial Discharge Permit - St. Joseph Energy CenterFYI... St. Joseph Energy Center's permit includes the following requirements found within the discharge permit.
1) St. Joseph Energy Center shall report flow daily.
2) St. Joseph Energy Center's Authorized Representative shall sign all reports including but not limited to Periodic
Compliance Reports (PCR), Slug Control Plans, Flow Measurement Plans, and corrective actions in response to
permit violations.
3) St. Joseph Energy Center shall, within 90 days of receipt of this discharge permit, submit a Slug Control Plan and
a Flow Measurement Plan. Please see Part III (E) and (H).
4) When collecting composite samples, samples must be obtained over a 24 hour period or for the duration of
discharge within the 24 hour sampling period including, if applicable, multiple batches.
5) Samples shall be obtained through a flow -proportional sampling technique. If St. Joseph Energy Center can
demonstrate that time -proportional sampling is as representative as flow -proportional sampling, then a time -
proportional sample may be collected. If St. Joseph Energy Center chooses to demonstrate that time -proportional
sampling is accurate they must do so within 120 days of the effective date of this permit or they shall commence
flow -proportional sampling at that time. Please see Part II (B) (1) of your wastewater discharge permit for details.
6) St. Joseph Energy Center shall have a Certified Operator for the State of Indiana sign all compliance reports
including, but not limited to PCR's, Corrective Action responses related to effluent limits violations.... See Part
III (F) (1).
7) To be submitted with the PCR, the Certified Operator shall sign one of the following statements: "Pretreatment
Standards and Requirements are being met on a consistent basis" or "Pretreatment Standards and Requirements
are not being met on a consistent basis. Additional operation and/or additional pretreatment is required to meet
the Pretreatment Standards and Requirements". Please see PART III (A) (3) (a).
8) Only the Authorized Representative shall be required to sign the certification statements found in Part III (A) (4)
of this permit.
9) Please review Section Part IV (B) (15), which clarifies the requirements concerning the Authorized
Representative.
10) For all after hours required oral notifications call: 574-277-8515 and dial zero (0) to reach an operator. See Part
III (I) of your permit for details.
If you have any questions, feel free to contact Manuel "Manny" Bueno at (574) - 235-5798 or
mbueno@southbendin.gov or Lauren Trapp at (574) 235-5852 or Itrapp@southbendin.gov.
1. Facility Description
St. Joseph Energy Center is an Electric Power Generation Facility that engages in the production of
electricity using natural gas in a combustion turbine. This facility will operate 24 hours 17 days per week
on two 12 hour shifts. The facility will be manned by 23 plant personnel.
2. Discharge Description
Generated discharge flows consist of total facility discharges (processes and equipment, facility wash -
downs, and sanitary). The estimated average discharge wastewater flow is 20,160 gpd. The metering
station is located in an above ground unit called a Hot Box to protect the meter from weather conditions,
inside the fence on SJEC property along Walnut Road and downstream of the OWS unit and domestic
sanitary connection.
3. Sample Site Description
Sample Site 4054 is located adjacent to the Hot Box location. Sample Site 4054 is considered to be end -
of -pipe.
4. Wastewater Treatment
Pretreatment of wastewater consists of an Oil Water Separator.
5. Classification
St. Joseph Energy Center may be classified as a Categorical Industrial User (CIU). Specifically, St.
Joseph Energy Center may be covered by the Steam Electric Power Generating Point Source under 40
CFR 423, The City's Industrial Pretreatment Program states that all Categorical Industrial Users be
classified at a minimum as a B. Pending Categorical applicability determination, St. Joseph Energy
Center is classified as a B industry.
6. Calculation of Limits
Wastewater discharged at Site #054 may be subject to the Categorical Standards at 40 CFR 423.17
(PSNS). Pending Categorical applicability determination, local limits have been applied where
appropriate as described in Chapter 17 of the City of South Bend Municipal Code.
7. Monitoring Frequency
Monitoring frequencies are based South Bend's US EPA approved Industrial Pretreatment Program
Monitoring Plan. However, more frequent monitoring will be required in the first year of new industrial
users.
Industrial Operator Certification Requirement
Industrial Operator Requirement: A -SO
Industrial operator certification requirements are based on the criteria listed in Indiana Administrative Code, Title 327, 5-
22-5.
03
City of South Bend
Department of Public Works
Industrial Pretreatment Program
Significant Industrial User — Permit No.
In accordance with all the terms of Chapter 17 of the City of South Bend's Municipal Code, and with any
applicable provisions of federal or state law and regulations, permission is hereby granted to:
St. Joseph Energy Center
54745 Walnut Road
New Carlisle IN 46552
for the contribution of wastewater into the City of South Bend Publicly Owned Treatment Works.
This permit is granted in accordance with the application filed on: __May 19 2017
Effective on: June 1,_2017
Expires on: December 1 2017
Revised:
Any violation of the terms and conditions of this permit shall be deemed a violation of the City of South Bend
Municipal Code and will subject the permittee to the sanctions set out in Section 17-11 through 17-13 of the
Municipal Code.
Approved By:
Board of Public Works
Gary A. Gilot, P.E.
Suzann M. Fritzber g
g
W,Wlk
Elizabeth A. Maradik
Therese orau
J es A. Mueller
CONTENTS
PART I EFFLUENT LIMITATIONS
PART II MONITORING REQUIREMENTS
PART III REPORTING REQUIREMENTS
PART IV STANDARD CONDITIONS
ATTACHMENT l DEFINITIONS
ATTACHMENT 2 ENFORCEMENT RESPONSE
PLAN
ATTACHMENT 3 PRIORITY POLLUTANT LIST
s
Facility Description:
St. Joseph Energy Center is an Electric Power Generation Facility that engages in the production of electricity
using natural gas in a combustion turbine process. This facility will operate 24 hours / 7 days per week on two
12 hour shifts. The facility will be manned by 23 plant personnel.
PART I -EFFLUENT LIl ff rATION:
A. Sample Port and Collection Location
Sample Outfall Site 4054 is located adjacent to the Hot Box location. Sample Site #054 is considered to be end -
of -pipe.
1. Any discharge of water or waste having a pH lower than 6.0 S.U. or a pH higher than 11.0 S.U. is prohibited.
In addition, the permittee's wastewater discharge shall not exceed the following effluent limitations:
Effluent Limitations for sample site #054:
Parameter _
Daily Maximum Limit (mg/L)
Arsenic (mg/L)
�- Report
�— `^--Mercury (mg/L)
_ -- 0.00019
Cadmium (mg/L)
F 0.2
Chromium (mg/L)
F ----- --- 1.0
Copper (mg/L)
_ 1.0
Cyanide (mg/L) I Report
Lead (mg/L)
0.5
Nickel (mg/1)
0.1
Oil and grease (mg/L)
300
Oil and Grease TPH (mg/L)�
100
Silver (mg/L)
F -T Report
Zinc (mg/L)
0.5
Priority Pollutants (mg/L)
Report
a. Daily Maximum Limit means the maximum allowable discharge limit of a pollutant during a calendar
day or any 24-hour period that represents a calendar day. Where Daily Maximum Limits are expressed
in units of mass, the daily discharge is the total mass discharged over the course of the day. Where
Daily Maximum Limits are expressed in terms of a concentration, the daily discharge is the arithmetic
average measurement of the pollutant concentration derived from all measurements taken that day. In
the case of samples collected by the grab method, the daily maximum shall be applied as an
Instantaneous Maximum Allowable Discharge Limit or as an Instantaneous Minimum Allowable
Discharge Limit as follows:
i. Instantaneous Maximum Allowable Discharge Limit— shall mean the maximum concentration or
loading of a pollutant allowed to be discharged at any time, determined from analysis of any grab
or composite sample collected, independent of the industrial flow rate and the duration of the
sampling event.
H. Instantaneous Minimum Allowable Discharge Limit -- shall mean the minimum concentration of
a pollutant allowed to be discharged at any time, determined from analysis of any grab or
composite sample collected, independent of the industrial flow rate and the duration of the
sampling event, The lower pH limit is applied as an Instantaneous Minimum Allowable
Discharge Limit.
2. Monthly Average Limit means the maximum allowable average of daily discharges over a calendar month,
calculated as the sum of the concentrations of all daily discharges measured during a calendar month divided
by the number of daily discharges measured that month.
3. Discharge ,Screening Level Limitations have been established to evaluate the need for a limitation for
pollutants that are not listed in the Effluent Limitation section of the permit. If a permittee has no limit for a
particular pollutant, but observes, through monitoring and analysis, a concentration of that pollutant greater
than the listed Discharge Screening Level concentration found in the table below, the permittee shall notify
the Control Authority, This notification shall be made in writing within five days of observing the pollutant
concentration.
Parameter F iiaily Maximum Screening Level (mg/L)
(Arsenic (mg/L)
0.2
Cadmium (mg/L)
0.1
Chromium (mg/L)
2.0
Copper (mg/L) - - - -
Cyanide (mg/L) 1
0.3
0.1
Lead (mg/L) 0.3
Nickel (mg/L)
0.3
Silver (mg L.)
0.2
Zinc (zng/L) 0.3
PART II - MONITORING REQUIRMENTS
A. Monitoring Frequency
1. The following parameters shall be monitored at the frequency and with the sampling type stated
below. All measurements, tests, and analyses of the characteristics of water and wastes to which
reference is made in this permit shall be conducted using the methods and procedures approved
in 40 CFR 136 and amendments thereto, unless otherwise specified in an applicable Categorical
Pretreatment Standard.
The following parameters shall be monitored at site #054 with the methods and at the frequency stated below:
Parameter
Sampling Sampling
Frequency Type
Flow Monthly (gal) �
j Monthly
Continuously
Flow, total (gpd)
Daily
Continuously
- Arsenic (mg/L)
Weekly
Composite
Cadmium (mglL)
Chromium (mg/L)
Weekly
Weekly
Composite
Composite
Copper (mg/L)
M Weekly -
Composite
Lead (mg/L)
Weekly
Composite
Nickel (mg/1) I Weekly
Composite
F — Zinc (mg/L) —[--Weekly
Composite
[_Ammonia, nitrogen (mg/L) Monthly
Composites
BOD5 (mg/L)
Monthly
Composite
Oii and grease (mg/L)
F Monthly
I Grab
Oil and Grease TPH (mg/L)
Monthly
Grab
pH (SU)
Monthly
F Grab
Phosphorus (mg/L)
F Monthly
Composite
[Total Suspended Solids (mg/L)
( Monthly
Composite
Cyanide (mg/L)
Semiannual
Grab
Mercury (mg/L)
Semiannual
F Composite
Silver (mg/L}
[ Semiannual
Composlte�l
Priority Pollutants (mg/L)
Semiannual
Grab
See Flow Measurement Requirements referenced in Part III - Reporting Requirements.
B. Monitoring Definitions
1. Composite — Samples are obtained through flow -proportional sampling technique over a 24-hour
period or for the duration of discharge within the 24-hour sampling period, including multiple
batches of wastewater. If, within 120 days of the effective date of this permit, the permittee
demonstrates that time -proportional sampling is accurate or as representative as flow -proportional
sampling, then a time -proportional sample may be collected.
2. Grab Sample — A single sample collected from a wastestream without regard to the flow in the
wastestream and over a period of time not to exceed fifteen (15) minutes and taken at a time
representative of normal discharge.
3. Continuously — The permittee shall monitor the discharge flow continuously and submit totalized
daily flows with the Periodic Compliance Report (PCR). Each ' PCR shall include all flow
measurements for the entire monitoring period covered in the report. This flow information shall
be in addition to the flow data collected during sampling which shall be measured from the start
of the sampling event to the end of the sampling event.
4. Daily monitoring frequency requires sampling to be conducted one (1) time in each calendar day.
5. Weekly monitoring frequency requires sampling to be conducted one (1) time in each calendar
week (Sunday to Saturday).
6. Monthly monitoring frequency requires sampling to be conducted a minimum of one (1) time per
calendar month.
7. Semiannual monitoring frequency requires sampling to be conducted a minimum of one (1) time
per semiannual period (111 Semiannual Period: January- June/2nd Semiannual Period: July -
December).
8. Quarterly monitoring frequency requires sampling to be conducted a minimum of one (1) time
per calendar quarter (I" Quarter: January -March/ 2nd Quarter: April -June/ 3rd Quarter: July -
September/ 4ch Quarter: October -December).
9. The following conventional pollutants shall incur a surcharge in excess of the stated limitations
below, as stated in Section 17-23(b) of the City of South Bend's Municipal Code.
Surcharge for ammonia (NH3-N) >25 mg/L
Surcharge for BOD5 >250 mg/L
Surcharge for phosphorus > I0 mg/L
Surcharge for Total Suspended Solids (TSS) >250 mg/L
C. Representative Sampling
l . Sampling shall be carried out by customarily accepted methods to reflect the effect of constituents
upon the sewage works and to determine the existence of hazards to life, limb and property.
2. All wastewater samples must be representative of the permittee's discharge.
3. Wastewater monitoring and flow measurement facilities shall be properly operated, kept clean, and
maintained in good working order at all times.
a. The failure of a permittee to keep its monitoring facility in good working order shall not be
grounds for the permittee to claim that sample results are unrepresentative of its discharge.
PART III- REPORTING REQUIREMENTS
A. Monitoring Reports
Monitoring results obtained shall be summarized and reported on an Industrial User Periodic
Compliance Report (PCR), The PCRs are due on the twentieth (20"') dog of the month following the
required monitoring time frame.
2. The PCR shall indicate the nature and concentration of all pollutants in the effluent for which
sampling and analysis were performed during the monitoring time frame preceding the submission
of each report, including measured flows. The PCRs shall also include all supporting documentation
necessary to demonstrate compliance.
3. The PCR shall be signed by a Certified Industrial Wastewater Operator of the State of Indiana
indicating whether Pretreatment Standards and Requirements are being met on a consistent basis,
and if not whether additional operation and maintenance and/or additional pretreatment is required
to meet the Pretreatment Standards and Requirements.
a. The Certified Operator shall sign one of the following statements:
"Pretreatment Standards and Requirements are being met on a consistent basis."
Or
"Pretreatment Standards and Requirements are not being met on a consistent basis. Additional
operation and maintenance and/or additional pretreatment is required to meet the Pretreatment
Standards and Requirements."
4. All reports, including but not limited to PCRs, the Flow Measurement Plan, the Slug Control Plan,
and corrective actions in response to permit violations, shall include the following certification
statement signed by an Authorized Representative. See Part IV (13)(15) of this permit foi
requirements concerning the Authorized Representative.
"I certify under penalty of law that this document and all attachments were prepared under my direction
or supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible for gathering the information, the information submitted is to the best
of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties
for submitting false information, including the possibility of fine and imprisonment for knowing
violations."
a. If the designation of an Authorized Representative is no longer accurate because a different
individual or position has responsibility for the overall operation of the facility or overall
responsibility for environmental matters for the company, a new written authorization must be
submitted to the Director prior to or together with any reports to be signed by the Authorized
Representative.
B. Additional Sampling
1. If the permittee monitors their wastewater discharge for any pollutant more frequently than required
by this permit, using test procedures in 40 CFR 136 or amendments thereto or otherwise approved
by U.S EPA or as specified in the permit, the results of such monitoring shall be included in any
calculations of actual daily maximum or monthly average pollutant discharge, and results shall be
reported in the -specific time frame report submitted to the Control Authority.
C. Notification of Batch or Infrequent Discharge
Within 30 days of the effective date of this permit, the permittee shall commence to notify the City
of South Bend via e-mail twenty-four (24) hours in advance of all batch or infrequent discharges to
the City's sewer so that during this time compliance monitoring may be conducted. The subject line
shall include the words "discharge notification" followed by the outfall number, anticipated time of
discharge, and the anticipated volume of discharge. The permittee may request a modification of
notification requirements. All requests for modification of notification requirements are subject to
approval by the City of South Bend. The notification shall be made via e-mail to
Pretreatment2SouthBendlN. Gov.
D. Noncompliance Notification and Re -Sampling
1. The permittee shall notify the Control Authority immediately of discharges that may cause problems
to the POTW, including any slugload or accidental discharge.
2. If sampling performed by the permittee indicates a violation, the permittee shall:
a. notify the Control Authority orally within twenty-four (24) hours of becoming aware of the
violation and;
b, submit a written follow up report within five (5) days of becoming aware of the violation and;
c. resample and submit the results of that analysis to the Control Authority within thirty (30) days
after becoming aware of the violation.
3. The permittee shall notify the Control Authority of any other noncompliance with this permit, not
described in D(1) and D(2) above, in writing within five (5) days of becoming aware of the
noncompliance.
E. Accidental Discharge/Slug Discharge Control
As required by Section 17-10 (b) of the South Bend Municipal Code: within ninety (90) days of the
effective date of this permit the permittee shall submit an Accidental Discharge/Slug Control Plan or
report as to whether the existing plan is still being implemented. Thereafter, this plan shall be
updated by the 30111 of November on a continuous even two (2) year cycle (i.e. 2014, 2016,
2018...). If an updated plan is not received by the date listed above, a $500.00 fine may be assessed
followed by a $500.00 fine for every month following, until an updated Accidental Discharge/ Slug
Control Plan is submitted. The Accidental Discharge/ Slug Control Plan shall address, at a minimum,
the following:
a. Description of discharge practices, including non -routine batch discharges.
b. Description of stored chemicals.
c. Procedures for immediately notifying the Director of any accidental or slug discharge, as required
hereafter.
d. Procedures to prevent adverse impact from any accidental or slug discharge. Such procedures
include, but are not limited to:
L inspection and maintenance of storage areas.
ii. handling and transfer of materials.
iii. loading and unloading operations.
iv. control of plant site runoff.
v. worker training
vi. building of containment structures or equipment.
vii. measure for containing toxic organic pollutants, including solvents.
viii. measures and equipment for emergency response.
2. The permittee shall orally notify the Control Authority immediately upon the occurrence of a slug or
accidental discharge of prohibited substances. The notification shall include location of discharge,
date and time of occurrence, type of waste, concentration and volume, and corrective action.
Immediate notification shall be verbal followed by a written verification within five (5) days of the
incident.
3. The permittee shall notify the Control Authority immediately if any changes occur at the facility that
affect the potential for a slug or accidental discharge. Additionally, the permittee shall submit a
revised plan that reflects those changes.
4. Once submitted, the Accidental Discharge/Slug Control Plan shall be deemed an enforceable part of the permit
and shall be implemented as written. Any deviation from the Accidental Discharge/Slug Control Plan shall
constitute a permit violation.
F. Certified Operator Requirement:
1. As required by Section 17-10 (o)(4)(b) of the South Bend Municipal Code:
St. Joseph Energy Center
New Carlisle IN 46552
(Hereafter "permittee") shall be required to have a Certified Industrial Wastewater Operator of the State of Indiana
with the minimum classification listed below, sign all periodic compliance reports, 90 day compliance status
reports, all compliance schedule reports, and all corrective actions related to an effluent limitations violation,
indicating whether Pretreatment Standards are being met on a consistent basis, and if not whether additional
operation and maintenance and/or additional pretreatment is required to meet the Pretreatment Standards and
Requirements.
Industrial Certified Operator Classification: A -SO
2. This permit holder shall have a certified operator, with the minimum classification listed above, sign
all periodic compliance reports, 90 day compliance status reports, all compliance schedule reports,
and all corrective actions related to an effluent limitations violation.
3. If a certified operator is not signing peimittee's user reports, a $500.00 fine will be assessed followed
by a $500.00 fine for every user report submitted, until the certified operator requirement is met.
G. Significant Change in Discharge / or Production
1. The permittee shall notify the Control Authority of any significant changes to the permittee's
operations or system which might alter the nature, quality, or volume of its wastewater at least thirty
(30) days before the change.
2. For permittees subject to categorical production based mass standards, average rates of production
shall be reported in the months of July and January. If at any time the permittee becomes aware that
the average production rate has changed or will change by twenty (20) percent or more, the permittee
shall notify the Control Authority regarding the change.
a. Any permittee operating under a permit incorporating equivalent mass or concentration limits
calculated from a Production -Based Standard shall notify the Director within two (2) business
days after the permittee has a reasonable basis to know that the production level will significantly
change within the next calendar month. Any permittee not notifying the Control Authority of
such anticipated change will be required to meet the mass or concentration limit in its permit that
were based on the original estimate of the long-term average production rate.
H. Flow Measurement Devices
1. The permittee shall submit a Flow Measurement Plan (FMP) within 90 days of the issuance of this
permit. The FMP shall describe, at a minimum, how the permittee will measure and record water
and wastewater flow in their facility, including how wastewater discharged to the sewer will be
measured. The FMP shall also describe how the flow of any internal processes will be measured
when such measurement is required. The IMP shall be subject to review by the Control Authority.
The permittee shall measure and report the wastewater discharge flow for the duration of each
sampling event. Totalized daily flows shall also be submitted with the Periodic Compliance Report
(PCR). For batch discharges, the permittee shall report the date and the volume of each and every
batch discharge. Each PCR shall include all flow measurements for the entire monitoring period
covered in the report.
3. The permittee shall calibrate any flow measurement device as needed, but no less than once annually.
The calibration shall be performed by a qualified individual, with the appropriate equipment, and by
a method acceptable to the Control Authority. The permittee shall submit all records of calibration
to the Control Authority.
4. Spare level sensing and totalizing/recording instrumentation, and sampling repair parts shall be
available for immediate installation upon discovery that flow measurement devices are not operating
properly, or as described in the FMP.
5. The permittee shall not, at any time, remove, alter, or change any of the flow measurement devices
described in the FMP. Any proposed change to the FMP shall be submitted to the Control Authority
for approval. If the permittee is unable to measure flow as described in the FMP, the permittee shall
immediately notify the Control Authority.
I. Reporting Information and Correspondence with the Permittee
1. Unless otherwise provided in this permit, all correspondence related to this wastewater discharge
permit shall be sent to the Control Authority at this address:
City of ,South Bend
Division of Environmental Services
Industrial Pretreatment Group
3113 Riverside Dr.
South Bend IN 46628
2. In the event that an oral notification is required the permittee shall call 574-277-851 S and dial zero
(0) to reach an operator.
3. All correspondence from the Control Authority to the permittee regarding compliance with this
permit will be directed to the Authorized Representative identified in the application in Question
A.3. The permittee shall be responsible for all requirements and information in correspondence
directed to the attention of this designated individual, including but not limited to due dates.
a. Should the permittee wish to change the Authorized Representative responsible to receive
correspondence from the Control Authority a written designation must be submitted to the Control
Authority indicating the name of the new Authorized Representative designated to receive
compliance correspondence, their position in the company, a statement that they meet the
requirements in part IV (15) of this permit, complete contact information, and an effective date of
this designation.
PART IV — STANDARD CONDITIONS
A. Prohibited Discharges
1. General prohibitions. No permittee shall introduce or cause to be introduced into the POTW any
pollutant or wastewater which causes Pass Through or Interference.
2. Specific prohibitions. No permittee shall introduce or cause to be introduced certain pollutants,
substances, or wastewater into any public sewers or directly or indirectly into the POTW. Those
pollutants, substances or wastewater prohibited by this subsection shall not be processed or stored in
such a manner that they could be discharged to the POTW. The following described pollutants are
expressly prohibited:
a. Any gasoline, benzene, naphtha, fuel oil or other pollutants which create afire or explosive hazard
to the POTW, including, but not limited to, wastestreams with a closed -cup flashpoint of less than
one hundred forty (140) degrees Fahrenheit (sixty (60) degrees Celsius) using the test methods
specified in 40 CFR 261.21.
b. Any wastewater containing toxic pollutants in sufficient quantity, either singly or by interaction
with other pollutants, to injure or interfere with any wastewater treatment process, constitute a
hazard to humans or animals, create a toxic effect in the receiving waters of the wastewater works,
or to exceed the limitations set forth in the applicable Federal Categorical Pretreatment Standards
or other pretreatment standards or regulation issued by the EPA or the IDEM. Toxic pollutants
are identified pursuant to Section 307(a) of the Federal Water Pollution Control Act, as amended.
c. Solid or viscous substances in quantities or of such size capable of causing obstruction to the flow
in sewers, or other interference with the proper operation of the sewage works such as, but not
limited to ashes, cinders, sand, mud, straw, shavings, metal, glass, rags, feathers, tar, plastics,
wood, unground garbage, whole blood, paunch manure, hair and fleshings, entrails, paper, dishes,
cups, milk containers, etc., either whole or ground by garbage grinders.
d. Any pollutant, including oxygen -demanding pollutants (BOD, etc.), released in a discharge at a
flow rate and/or pollutant concentration which, either singly or by interaction with other
pollutants, will cause interference with the POTW.
e. Wastewater or any liquid having a temperature greater than one hundred fifty (150) degrees
Fahrenheit (sixty-five (65) degrees Celsius), or which will inhibit biological activity in the
treatment plant resulting in interference, but in no case wastewater or liquid which causes the
temperature at the introduction into the treatment plant to exceed one hundred four (104) degrees
Fahrenheit (forty (40) degrees Celsius).
f. Trucked or hauled pollutants, except at discharge points designated by the Director.
g. Any pollutant that results in the presence of toxic gases, vapors, or fumes within the POTW in a
quantity that may cause acute worker health and safety problems.
h. Any radioactive wastes or isotopes of such half-life or concentration as may exceed limits
established by the Board in compliance with applicable State or Federal regulations.
Any water or waste containing Total Oil and Grease (biodegradable animal and vegetable fats,
oil, waxes and greases and non -biodegradable hydrocarbon oils and greases), whether emulsified
or not, in excess of three hundred (300) mg/L, Total Oil and Grease. The hydrocarbon portion of
the Total Oil and Grease concentration may not exceed one hundred (100) mg/L. Proper testing
procedures shall be outlined for each permittee. No permittee shall introduce or cause to be
introduced petroleum oil, non -biodegradable cutting oil, or products of mineral oil origin, in
amounts that will cause Pass Through or Interference.
j. Any garbage that has not been properly shredded. The installation and operation of any garbage
grinder equipped with a motor of three -fourths -horsepower (0.76 hp metric) or greater shall be
subject to the review and approval of the Board.
k. Any waters or wastes containing strong acid iron pickling wastes or concentrated plating solutions
whether neutralized or not.
1. Any waters or wastes containing iron, chromium, copper, zinc and similar objectionable or toxic
substances; or wastes exerting an excessive chlorine requirement, to such degree that any such
material received in the composite sewage at the sewage treatment works exceeds the limits
established by the Director for such materials.
in, Any waters or wastes containing phenols or other taste- or odor -producing substances, in such
concentrations exceeding limits which may be established by the Board as necessary, after
treatment of the composite sewage, to meet the requirement of the State, Federal or other public
agencies of jurisdiction for such discharge to the receiving waters.
n. Any waters or wastes having a pH lower than 6.0, any waters or wastes having a pH in excess of
11.0, or having any corrosive property capable of causing damage or hazard to structures,
equipment, or personnel of the publicly owned treatment works (POTW), or that interferes with
any treatment process.
o. Noxious or malodorous liquids, gases, solids, or other wastewater which, either singly or by
interaction with other wastes, are sufficient to create a public nuisance or a hazard to life, or to
prevent entry into the sewers for maintenance or repair.
p. Sludges, screenings, or other residues from the pretreatment of industrial wastes.
q. Medical Wastes, except as specifically authorized by the Director.
Wastewater causing, alone or in conjunction with other sources, the POTW's effluent to fail a
toxicity test.
s. Materials which exert or cause:
i. Unusual concentrations of inert suspended solids (S.S.) (such as, but not limited to, Fullers
earth, lime slurries and lime residues) or of dissolved solids (such as, but not limited to, sodium
chloride and sodium sulfate).
ii. Excessive discoloration (such as, but not limited to, dye wastes and vegetable tanning
solutions).
iii. Unusual S.S., CBOD, BOD, ammonia -nitrogen, phosphorus, or chlorine requirements in such
quantities as to constitute a significant load on the sewage treatment works.
iv. Unusual volume of flow or concentration of wastes constituting "slugs," as defined herein.
t. Waters or wastes containing substances which are not amenable to treatment or reduction by the
sewage treatment processes employed, or are amenable to treatment only to such degree that the
sewage treatment plant effluent will be compromised.
u. It shall be unlawful for any permittee to place, deposit, permit to be deposited, or discharged in
any manner whatsoever, any substance into a sewer at a point different than the proposed sewer
connection to the sanitary sewer system.
3. Dilution Prohibition. No permittee shall ever increase the use of process water, or in any way attempt
to dilute a discharge as a partial or complete substitute for adequate treatment to achieve compliance
with a discharge limitation unless expressly authorized by an applicable Pretreatment Standard or
Requirement. The Director may impose mass limitations on permittees who are using dilution to
meet applicable Pretreatment Standards or Requirements or in other cases when the imposition of
mass limitations is appropriate.
4. Right of Revision. The City reserves the right to establish by ordinance or in individual wastewater
discharge permits, more stringent standards or requirements on discharges to the POTW consistent
with the purpose of the Pretreatment Program.
B. General Pretreatment Requirements
1. Power and Authority of Inspectors
a. The Director, Inspector and other duly authorized employees of the City bearing proper
credentials and identification shall be permitted to enter all properties for the purpose of
inspection, observation, measurement, sampling, and testing in accordance with the provisions of
the City of South Bend's Municipal Code. The Director or his representative shall have no
authority to inquire into any processes including metallurgical, chemical, oil, refining, ceramic,
paper or other industries that do not have a direct bearing on the kind and source of discharge to
the sewers or waterways of facilities for waste treatment.
b. While performing the necessary work on private properties, the Director or duly authorized
employees of the City shall observe all safety rules applicable to the premises established by the
company and the company shall be held harmless for injury or death to the City employees and
the City shall indemnify the company against loss or damage to its property by City employees
and against liability claims and demands for personal injury or property damage asserted against
the company and growing out of the gauging and sampling operation, except as such may be
caused by the negligence or failure of the company to maintain safe conditions in their facility.
The Director and other duly authorized employees of the City bearing proper credential and
identification shall be permitted to enter all private properties through which the City holds a duly
negotiated easement for the purpose of, but not limited to, inspection, observation, measurement,
sampling, repair and maintenance of any portion of the sewage works lying within said easement.
All entry and subsequent work on said easement shall be done in full accordance with the terms of the
duly negotiated easement pertaining to the private property involved.
2. Facilities Operation
a. The permittee shall at all times maintain in good working order and operate as efficiently as
possible, all pretreatment or control facilities or systems installed or used by the permittee to
achieve compliance with the terms and conditions of this permit.
3. BWassin
a. The permittee may allow any bypass (i.e., an intentional diversion of any wastestream from any
portion of the permittee's treatment facility) to occur that does not cause any Pretreatment
Standards or Requirements to be violated, provided that the bypass is for maintenance essential
to assure efficient operation of the facility.
b. Any other bypass is prohibited except:
i. where it would be unavoidable to prevent loss of life, personal injury or severe property
damage. Severe property damage means substantial physical damage to property, damage to
the treatment facilities which causes them to become inoperable or substantial and permanent
loss of natural resources which can reasonably be expected to occur in the absence of a bypass.
Severe property damage does not mean economic loss caused by delays in production.
ii. where there was no feasible alternative to the bypass, such as the use of auxiliary treatment
facilities, retention of untreated wastes, or maintenance during normal periods of equipment
downtime (this condition is not satisfied if, in the exercise of reasonable engineering judgment,
adequate back-up equipment should have been installed to prevent a bypass during normal
periods of equipment downtime or preventative maintenance); and
iii. where the permittee has submitted notice to the control authority as required below.
c. If the permittee knows in advance of the need to bypass, the permittee shall provide verbal notice
to the Control Authority, if possible, at least ten (10) days before the date of bypass. In the event
of an unanticipated bypass, the permittee shall notify the Control Authority of any bypass that
violates any Pretreatment Standard or Requirement within twenty-four (24) hours of becoming
aware of the bypass. Within five (5) days of becoming aware of the bypass, the permittee must
submit a written report to the Director, unless waived by the Director, containing;
i. a description of the bypass and its cause;
ii. the duration of the bypass, including exact dates and times, and if the bypass has not been
corrected, how long the bypass is expected to continue; and
iii, steps taken or planned to reduce, eliminate, and prevent reoccurrence of the bypass.
4. Duty to Mitigate
a. The permittee shall take all reasonable steps to minimize any adverse impact to the POTW
resulting from noncompliance with any effluent limitations specified in this permit, including
such accelerated or additional monitoring necessary to determine the nature and impact of the
non -compliant discharge.
5. Upset Provision
a. Upset means an exceptional incident in which there is unintended and temporary noncompliance
with categorical Pretreatment Standards because of factors beyond the reasonable control of the
permittee. An upset does not include noncompliance to the extent caused by operational error,
improperly designed treatment facilities, inadequate treatment facilities, lack of preventative
maintenance, or careless or improper operation.
b. An upset shall constitute an affirmative defense to an action brought for noncompliance with
categorical Pretreatment Standards if the requirements below are met.
c. A permittee who wishes to establish the affirmative defense of upset shall demonstrate, through
properly signed contemporaneous operating log, or other relevant evidence that:
i. an upset occurred and the permittee can identify the cause(s) of the upset
ii. the facility was at the time being operated in a prudent workman -like manner and in
compliance with applicable operation and maintenance procedures; and
iii. the permittee has submitted the following information to the Director within twenty-four (24)
hours of becoming aware of the upset (if this information is provided orally, a written
submission must be submitted within five (5) days):
a. a description of the discharge and cause of noncompliance;
b. the period of noncompliance, including exact dates and times, or, if not corrected, the anticipated
time the noncompliance is expected to continue; and
c. the steps being taken and/or planned to reduce, eliminate, and prevent recurrence of the
noncompliance.
d. In any enforcement proceeding, the permittee seeking to establish the occurrence of an upset shall
have the burden of proof.
e. The permittee shall have the opportunity for a judicial determination on any claim of upset only
in an enforcement action brought for noncompliance with categorical Pretreatment Standards.
f. The permittee shall control production of all discharges to the extent necessary to maintain
compliance with categorical Pretreatment Standards upon reduction, loss, or failure of its
treatment facility until the facility is restored or an alternative method of treatment is provided.
This requirement applies in the situation where, among other things, the primary source of power
of the treatment facility is reduced, lost, or fails.
6. Administrative En orcement
a. Any permittee found in violation of any applicable local, state, federal law, City of South Bend
Municipal Code Chapter 17, or any conditions within this permit will be subject to Administrative
Enforcement Action in accordance with the Enforcement Response PIan (ERP) provided in
Attachment 2 to this permit.
7. Penalties for False Reporting
a. Any person who knowingly makes any false statement, representation or certification in any
application, record, report, plan or other document filed or required to be maintained pursuant to
this permit, or who falsifies, tampers with, or knowingly renders inaccurate any monitoring device
or method required under this permit, shall be subject to administrative fines of not more than
$2500 per day per violation and/or civil litigation and/or fines and imprisonment upon criminal
conviction.
8. Penalties for Violation of Pretreatment Standards
a. Any permittee found in violation of Pretreatment Standards and Requirements (40 CFR 403), the
City of South Bend Municipal Code, or this industrial wastewater discharge permit issued by the
City of South Bend and any applicable compliance schedules, shall be subject to administrative
fines of not more than $2500 per day per violation and/or civil litigation and/or fines and
imprisonment upon criminal conviction.
9. Revocation of Permit
a. The Director may revoke an individual wastewater discharge permit for good cause, which shall
be subject to appeal under Article 2, Chapter 17, Subsection 17-1 I(c) of the South Bend
Municipal Code, but the effectiveness of revocation shall not be stayed pending administrative
appeal. Reasons for permit revocation by the Director include, but are not limited to the
following:
i. Failure to notify the Director of significant changes to the wastewater prior to the changed
discharge;
ii. Failure to provide prior notification to the Director of changed conditions pursuant to Article
2, Chapter 17, Subsection 17-10(o)(5);
iii. Misrepresentation or failure to fully disclose all relevant facts in the wastewater discharge
permit application;
iv. Falsifying periodic compliance reports and certification statements;
v. Tampering with monitoring equipment;
vi. Refusing to allow the Director timely access to the facility premises and records;
vii. Failure to meet effluent limitations;
viii. Failure to pay fines;
ix. Failure to pay sewer charges;
x. Failure to meet compliance schedules;
xi. Failure to complete a wastewater discharge survey or the wastewater discharge permit
application;
xii. Failure to provide advance notice of the transfer of business ownership of a permitted facility;
or
xiii. Violation of any Pretreatment Standard or Requirement, or any terms of this permit or Chapter
17 of the City of South Bend's Municipal Code.
10. Confidentiality
a. Information and data on a permittee obtained from reports, surveys, wastewater discharge permit
applications, individual wastewater discharge permits and monitoring programs, and from the
Director's inspection and sampling activities, shall be available to the public without restriction,
unless the permittee specifically requests, and demonstrates, to the satisfaction of the Director,
that the release of such information would divulge information, processes, or methods of
production entitled to protection as trade secrets under the Indiana Access to Public Records Act
(IC 5-14-3-4(A)(4)). Any such request must be asserted at the time of submission of the
information or data by stamping the words "confidential business information" on each page
containing such information. When requested and demonstrated by the permittee furnishing a
report that such information should be held confidential, the portions of a report which might
disclose trade secrets or secret processes shall not be made available for inspection by the public,
but shall be made available immediately upon request to governmental agencies for uses related
to the NPDES program or pretreatment program, and in enforcement proceedings involving the
person furnishing the report.
b. Wastewater constituents and characteristics and other effluent data, as defined at 40 CFR 2.302
shall not be recognized as confidential information and shall be available to the public without
restriction.
c. All other information which is submitted to the State or Board of Public Works shall be available
to the public at least to the extent provided by 40 CFR 2.302.
11. Transfer of Ownership or Control
a. This permit may be transferred to a new owner or operator only if the permittee gives at least
thirty (30) days advance notice to the Director and the Director approves the individual
wastewater discharge permit transfer. The notice to the Director must include a written
certification by the new owner or operator which:
L Identifies the new owner or operator, including address and telephone number;
ii. Identifies the Authorized Representative for the new owner or operator in accordance with Part
IV (B)(1 S) of this permit, including telephone number and email address;
iii. States that the new owner and/or operator has no immediate intent to change the facility's
operations and processes;
iv. Identifies the specific date on wbich the transfer is to occur; and
v. Acknowledges full responsibility for complying with the existing individual wastewater
discharge permit.
b. Failure to provide advance notice of a transfer renders this permit void as of the date of transfer.
12. Reopening Clause
a. This permit shall be modified, or alternatively, revoked and reissued, to comply with any
applicable effluent limitation or standard issued or approved under section 307(b) of the Clean
Water Act if the effluent limitation or standard so issued or approved:
i. Contains different conditions or is otherwise more stringent than any effluent limitation in the
permit; or
ii. Controls any pollutant not limited in the permit.
b. The permit, as modified or reissued under this paragraph, shall also contain any other
requirements of the Clean Water Act when applicable.
13. Records Retention
a. Permittee's shall retain, and make available for inspection and copying, all records of information
obtained pursuant to any monitoring activities required by this permit, any additional records of
information obtained pursuant to monitoring activities undertaken by the permittee independent
of such requirements, and documentation associated with Best Management Practices established
under Section 17-5 of the South Bend Municipal Code. Records shall include the date, exact place,
method, and time of sampling, and the name of the person(s) taking the samples; the dates
analyses were performed; who performed the analyses; the analytical techniques or methods used;
any information used to demonstrate that the analysis was performed in accordance with methods
approved in 40 CFR Part 136; and the results of such analyses. These records shall remain
available for a period of at least three (3) years. This period shall be automatically extended for
the duration of any litigation concerning the permittee or the City, or where the permittee has been
specifically notified of a longer retention period by the Director.
14. Federal and State Pretreatment Requirements
a. Compliance with this wastewater discharge permit does not relieve the permittee of responsibility
for compliance with all applicable Federal and State Pretreatment Standards, including those
which become effective during the term of this wastewater discharge permit.
15. Authorized Representatives
a. The permittee shall be represented by an Authorized Representative and/or Duly Authorized
Representative.
i. The Authorized Representative or Duly Authorized Representative of the permittee shall be:
a. If the Permittee is a corporation:
i. The president, secretary, treasurer, or a vice-president of the corporation in charge of a principal
business function, or any other person who performs similar policy or decision -making functions
for the corporation; or
ii. The manager of one (1) or more manufacturing, production, or operating facilities, provided the
manager is authorized to make management decisions that govern the operation of the regulated
facility including having the explicit or implicit duty of making major capital investment
recommendations, and initiate and direct other comprehensive, measures to assure long-term
environmental compliance with environmental laws and regulations; can ensure that the
necessary systems are established or actions taken to gather complete and accurate information
for individual wastewater discharge permit requirements; and where authority to sign documents
has been assigned or delegated to the manager in accordance with corporate procedures.
b. If the permittee is a partnership or sole proprietorship: A general partner or proprietor,
respectively.
c, if the permittee is a Federal, State, or local government facility: A director or highest official
appointed or designated to oversee the operation and performance of the activities of the
government facility, or their designee.
ii. The individuals described in paragraphs (a) through (c) above, may designate a Duly
Authorized Representative if the authorization is made in writing by the individual described
in (a) through (c) above, the authorization specifies either an individual or a position having
responsibility for the overall operation of the facility from which the Industrial Discharge
originates, such as the position of plant manager, operator of a well, or well field
superintendent, or a position of equivalent responsibility, or having overall responsibility for
environmental matters for the company, and the written authorization is submitted to the
Director.
ATTACHMENT I
Definitions
As used in this Industrial Discharge Permit:
Board: shall mean the City of South Bend acting through its Board of Public Works or duly authorized officials
or board acting in its behalf.
Calendar day: shall mean any 24-hour period that represents a calendar day for the purposes of sampling.
Certified Operator: shall mean a person certified by the state of Indiana to sign all user reports indicating whether
pretreatment standards are being met on a consistent basis, and if not whether additional operation and
maintenance and/or additional pretreatment is required to meet the Pretreatment Standards and Requirements.
Director: means the Director of Environmental Services of the City of South Bend, Indiana, or his authorized
deputy, agent or representative.
Control Authority or Industrial Pretreatment._ Group: shall mean the Bureau of Wastewater Division of
Environmental Services located at: 3113 Riverside Drive, South Bend, IN 46628.
Slu (g or slugload): shall mean any discharge at a flow rate or concentration which could cause a violation of the
prohibited discharge standards set forth in section 17-8 of the City of South Bend Municipal Code, herein, or any
discharge of a non -routine, episodic nature, including, but not limited to, an accidental spill or non -customary
batch discharge.
Batch or Infrequent Discharge: shall refer to the discharge produced from a treatment or manufacturing process
in which a tank or reactor is filled, the wastewater (or solution) is held or a chemical solution is prepared, and the
tank is emptied, resulting in a discrete discharge to the sanitary sewer. Batch or infrequent discharge shall also
mean wastewater produced due to cleaning, stabilizing, or conditioning chemical solutions for use in industrial
manufacturing and treatment processes as well as the discharge from processes that are not in operation on a
regular basis, and from occasional maintenance activities.
Batch Composite Sampling: A batch composite sample shall consist of at least three (3) grab samples that are
collected throughout the duration of the discharge from the batch tank. At a minimum, the samples shall be
collected at the beginning, the middle, and the end of the discharge from each batch tank.
ATTACHMENT 2
ENFORCEMENT
RESPONSE
CITY Or SOUTH BEND
INDUSTRIAL PRETREATMENT
Enforcement Response Plan Outline
1. Management Plan
A. Permit Application and Classification
B. Permitting
C. Monitoring
D. field Inspection and Analysis
E. Compliance Decisions and Enforcement
Ii. Enforcement Procedures
111. Significant Non -Compliance
IV. Enforcement Response Examples
A. Sampling, Monitoring, Reporting
B. Compliance Schedules
C. Discharge Limitations
D. Non -Compliance Detected Through Inspections or Field Investigations
E. Other Non -Compliance
V. Timeframes for Responses
Tlus Fidorcement Response Plata was written with the guidance of U.S. EPA document PB90-185083, Guidance
forDevelopiug Cofltro]AuthorltyTi orcemerjt Response P4uxs. Office of Water Enforcement and Permits.
U.S. Environmental Protection Agency, Washington, DC 20460 1989.
Revised 4/29/2011
Approved by US EPA in a letter dated July 21, 2011
This document will describe the enforcement procedures that are used in controlling industrial discharges to the
South Bend Publicly Owned Treatment Works.
I. Management Plan
The pretreatment program for the City of South Bend is administered by the Division of Environmental Services.
The responsibilities of the pretreatment program are:
1. Collect and verify industrial discharge data through laboratory analyses.
2. Make recommendations to the Board of Public Works concerning the issuance of discharge permits.
3. Review user discharge monitoring reports.
4. Determine the status of user compliance with federal, state, and local regulations.
5. Write federal, state, and local mandated pretreatment reports.
6. Make recommendations for enforcement actions.
Enforcement procedures such as letters of violation, administrative fines, and administrative orders are issued by a
Pretreatment Coordinator. Pretreatment Coordinators recommend more serious enforcement responses to the
Environmental Compliance Manager and the Director of Environmental Services. Severe violations are reported
to the Board of Public Works witli recommendations from the Director of Environmental Services.
The following information describes in more detail d1e management procedures which are used in enforcement
of the program.
A. Permit Application and Classification
Lists of Industrial Users (IUs) are evaluated based on operations performed, water usage and discharge, and
chemical inventory, among other factors. Industries identified as belonging to one of the following groups are
issued industrial wastewater discharge permits, and categorized as either an Industrial User, or a Significant
Industrial User.
1. IT.Js subject to federal categorical standards - SIU
2. IUs that have process wastewater discharge exceeding 25,000 gallons per day - SIU
3. IUs that contribute process wastewater discharge exceeding 596 of the POTW's dry weather hydraulic or organic
loading capacity.- SIU
4. IUs that have a reasonable potential to adversely affect PO'1 VV workers, the POTW itself, and the receiving
stream. - SIU
5. IUs that have non -significant waste water discharge streams may or may not be issued an industrial wastewater
discharge permit. - IU/SIU
B. PennitUng
The pretreatment staff assesses (lie information supplied by a user in its permit application. Discharge parameters
to be monitored are set based on application information and local requirements, and limits are set in accordance
with local, state, and federal regulations. The industrial wastewater discharge permit is issued by the South Bend
Board of Public Works.
C. Monitoring
Monitoring consists prunarily 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 pern-i it.
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 anh.ouncement.
3. Compliance report submitted to the City of South Bend pretreatment stall as described in each permitted user's
discharge pern.it.
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 stall 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.
It. 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 die 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 die response.
The Enforcement Rcs"ise Plan groups various types of violations into die following four categories:
Violations of sampling, monitoring, and reporting
2. Violations of compliance schedules
3. Violations of discharge limitations
4. Violations detected through inspection or field monitoring
In order to provide a concise document in a usable format, abbreviations have been used for the types of
response. A definition of each abbreviation is listed in increasing order of severity.
1. IA - An Informal Action may be used to respond to minor violations. This is typically conveyed to the industry
contact person, either by phone or with a written notice. This type of response is used for very minor violations
that only require follow up action at the next compliance event.
2. LOV - A Letter of Violation is tine most widely used and is a written notification to the User indicating the type of
apparent violation. The LOV will require a response within 14 days which usually consists of a written letter to
the Control Authority (POTW - City of South Bend) indicating the reason for the noncompliance and a
description of measures that are being taken to eliminate similar future violations.
3. AF - An Administrative Fine is a monetary penalty assessed by the Control Authority for violations of
pretreatment standards and requirements. An administrative fine may not exceed $2,500 per day per violation and
the Control Authority has discretion in setting the amount of the fine. In the case of long term noncompliance, or
noncompliance with a long term average standard, a fine shall accrue for each day of the period of
noncompliance.
4. AO - An Administrative Order is issued to a User by the Control Authority and contains necessary corrective
measures that need to be carried out by a User to achieve compliance. The four basic types of administrative
orders are: Cease and Desist, Consent, Show Cause, and Compliance. A description of each follows. The order
would normally contain a short time frame.
a. Cease and Desist - When tine Director fords that a User has violated, or continues to violate, any provision of this
ordinance, an individual wastewater discharge permit, or order issued hereunder, or any other Pretreatment
Standard or Requirement, or that the Users past violations are likely to recur, the Director may issue an order to
the User directing it to cease and desist all such violations and directing the User to:
(1) Immediately comply with all requirements; and
(2) Take such appropriate remedial or preventive action as maybe needed to properly address a continuing or
threatened violation, including halting operations and/or terminating the discharge. Issuance of a cease and desist
order shall not be a bar against, or a prerequisite for, taking any other action against the User.
b. Consent -The Director may enter into Consent Orders, assurances of compliance, or other similar documents
establishing an agreement with any User responsible for noncompliance. Such documents shall include specific
action to be taken by the User to correct die noncompliance within a time period specified by the document.
c. Show Cause - The Director may order a User which has violated, or continues to violate, any provision of this
ordinance, an individual wastewater discharge permit, or order issued hereunder, or any other Pretreatment
Standard or Requirement, to appear before the Director and show cause why the proposed enforcement action
should not be taken. Notice shall be served on the User specifying the time and place for the meeting, the proposed
enforcement action, the reasons for such action, and a request that the User show cause why the proposed
enforcement action should not be taken.
d. Compliance - When die Director finds that a User has violated, or continues to violate, any provision of this
ordinance, an individual wastewater discharge permit, or order issued hereunder, or any od-ier Pretreatment
Standard or Requirement, tine Director may issue an order to the User responsible for the discharge directing that
the User come into compliance within a specified time. If the User does not come into compliance within the time
provided, sewer service may be discontinued unless adequate treatment facilities, devices, or other related
appurtenances are installed and properly operated. Compliance orders also may contain other requirements to
address the noncompliance, including additional self-nnonitoring and management practices designed to minimize
the amount of pollutants discharged to the sewer. A compliance order may not extend dnc deadline for compliance
established f'or a Pretreatment Standard or Requirement, nor does a compliance order relieve the User of liability
for any violation, including any continuing violation.
5. LIT - Litigation is the most severe enforcement action and is utilized when a User has not cooperated with the
Control Authority or responded to the other enforcement remedies. Litigation defines several courses of action
including civil suits for injunctive relief and/or civil penalties, criminal suits, termination of service, etc. These
types of actions would all involve the courts and the City Attorney and would follow the procedures necessary for
the due process.
III. Significant Non Compliance (SNC)
Utilizing the Enforcement Response Plan, Pretreatment Staff will initiate the appropriate response and see that the
enforcement tracking files have been updated to show the type of action being taken and the response date.
On a quarterly basis the Pretreatment Staff will be responsible for reviewing the compliance file of all Industrial
Users for the previous six (6) months to determine significant non-compliance of any industrial user and on an
annual basis, the names of all Industrial Users found in significant non-compliance will be published in the South
Bend Tribune. A definition of significant non-compliance follows.
Instances of Significant Non -Compliance (SNC) are Industrial User Violations which meet one or more of the
following criteria:
(a) Chronic violations of wastewater Discharge limits, defined here as those in which sixty-six (66) percent or more
of all of the measurements taken for the same pollutant parameter during a six-month period exceed (by any
magnitude) a numeric Pretreatment Standard or Requirement, including instantaneous limits, as defined by 40 CFR
403.30);
(b) Technical Review Criteria (TRC) violations, defined here as those in which thirty-three (33) percent or more of
all of the measurements taken for tine same pollutant parameter during a six-month period equal or exceed the
product of the numeric Pretreatment Standard or Requirement including instantaneous limits, multiplied by the
applicable TRC (TRC = 1.4 for BOD, TSS, fats, oils and grease, and 1.2 for all other pollutants except pH);
(c) Any other violation of a Pretreatment Standard or Requirement that the Director determines has caused, alone
or in combination with other Discharges, Interference or Pass Through (including endangering the health ofPOTW
personnel or the general public);
(d) Any discharge of a pollutant that has caused imminent endangerment to human health, welfare, or to the
environment, or has resulted in the POTW's exercise of its emergency authority to halt or prevent such a discharge;
(e) Failure to meet, within nunety (90) days after the schedule date, a compliance schedule milestone contained in
local control mechanism or enforcement order for starting construction, completing construction, or attaining final
compliance;
(h Failure to provide, within thirty (30) days after the due date, required reports, such as baseline monitoring
reports, ninety (90) day compliance reports, periodic compliance reports, and reports on compliance with
compliance schedules;
(g) Failure to accurately report noncompliance;
(h) Any other violation or group of violations, which may include a violation of Best Management Practices, which
tine Director determines will adversely affect the operation or implementation of the local Pretreatment program.
Note: A determination of Significant Non -Compliance will not be made if the non-compliance events triggering
SNC occurred only in the first 3 month period of any 6 month period being evaluated, and if the events caused the
user to be in SNC for the previous 6 month period, If a user is found to be in SNC and continuing violations of
the same type occur in the following 6 month period, tine events from the previous quarter may be used in
determining SNC in the following period.
IV. Enforcement Response Plan Examples
A. Sampling, Monitoring, and Reporting
Non -Compliance Circumstances
Failure to sample, monitor
or report
Failure to sample, monitor,
report, and notify Control
Authority
Failure to sample, monitor,
report, and notify Control
Authority
Isolated., or infrequent
Isolated or infrequent
Frequent, or IU does not respond to
LOV
Range of Response
LOV requiring correction within 14
days, AF, AO
LOV requiring correction within 14
days, Escalated AF, AO
LOV, AF, AO, SNC
Failure to notify of effluent
limit violation, or slug
Isolated, or infrequent. No known
LOV, AF, AO if no response within 14
discharge
effects.
days
Failure to notify of effluent
limit violation
Frequent or continued violation
LOV, AF, AO, SNC, LIT
Failure to notify of effluent
limit violation, or slug
Known environmental or POTW
discharge
damage
LOV, AF, SNC, AO, Lit
Failure to submit renewal
permit application 90 days
prior to permit expiration
Number of days will be considered
LOV, AF
Reporting false information
Any instance
LIT, Criminal Investigation
B. Discharge Limitations
Nan -Compliance
Circumstances
Range of Response
Exceeding Final Limits
(categorical, local, or
prohibited)
Infrequent or isolated minor violation
LOV, AF
Infrequent or isolated major violations,
LOV & AF, AO, LIT if environmental
Exceeding Final Limits
exceed TRC limits
harm results
Exceeding Final Limits
Violation(s) which are SNC
AF, AO, LIT
Exceeding Interim Limits
No lunown damages
LOV, AF, AO
Results in known environmental or
Exceeding Interim Limits
POTW damage - SNC
LOV, AF, AO, LIT
Reported Slug load
Isolated, no known damage
LOV, Show cause, AF, AO
Isolated with known interference, pass
Reported Slug load
through or damage
LOV, AF, AO, LIT
Reported Slug load
Recurring - SNC
LOV, AF, AO, LIT
Discharge without permit or
approval
One time, no known damage
LOV, AO, AF
Discharge without permit or
LOV,AF, AO, LIT, or request for
approval
One time, results in damage
criminal investigation
Discharge without permit or
Continuing violation with known
LIT, request for criminal investigation,
approval
damage
sewer disconnect
C. Non-compliance detected through inspections or field investigation
Non -Compliance Circumstances Range of Response
Minor violation of analytical
procedures
Major violation of analytical
procedures
Major violation of analytical
procedures
Minor violation of permit
condition
Minor violation of permit
condition
Major violation of permit
condition
Any instance
No evidence of intent
Evidence of negligence or intent - SNC
No evidence of negligence or intent
Evidence of negligence or intent - SNC
Evidence of negligence or intent - SNC
LOV, AF with continuing violation
LOV, AF, AO
LOV, AF, AO, LIT (possible criminal
action)
LOV, immediate corrective action
required, AF
AF, AO, SNC, LIT (possible criminal
action)
AF, AO, SNC, LIT (possible criminal
action)
D. Compliance schedules
Non -Compliance Circumstances
Range of Response
Reporting false information
Any instance - SNC
LIT, criminal investigation
Will not cause late final or other interim
Missed interim date
date
LOV
Will result in other missed interim
Missed interim date
dates, violation for valid cause
LOV, AO
Will result in other missed interim
Missed interim date
dates, no valid cause - SNC
LOV, AO, LIT
90 days or more, failure or refusal to
Missed final date
comply without a valid cause
AO, LIT
V. Time frame for responses
A. Initial enforcement action responses [involving contact with industrial users and requesting information on corrective or
preventative action (s)] will occur within 15 days of becoming aware of violation.
B, Follow ❑p actions for continuing or recurring violations will be taken within sixty (60) days of the initial enforcement response.
For all continuing violations, the response will include an administrative order with milestones or deadlines.
C. Violations which threaten health, property, or envirotunental quality are considered emergencies and will receive immediate
responses such as halting the discharge or terminating service.
D. All violations meeting the criteria for Significant Non -Compliance will be addressed with an enforceable order within 30 days
of the identification of Significant Non -Compliance.
ATTACHMENT 3
Priority Pollutants List
Appendix A to Part 423 - Priority Pollutants
001 Acenaphthene
002 Acrolein
003 Acrylonitrile
004 Benzene
005 Benzidine
006 Carbon tetrachloride (tetra chloromethane)
007 Chlorobenzene
008 1,2,4-trich lorobenzene
009 Hexachlorobenzene
010 1, 2-d ich to roet h a n e
011 1,1,1-trichloreothane
012 Hexachloroethane
013 1,1-dichloroethane
014 1,1,2-trich loroethane
015 1,1,2,2-tetrachloroethane
016 Chloroethane
018 Bis(2-chloroethyl) ether
019 2-chloroethyl vinyl ether (mixed)
020 2-chloronaphthalene
0212,4, 6-trichlorophenol
022 Parachlorometa cresol
023 Chloroform (trichloromethane)
024 2-chlorophenol
025 1,2-dichlorobe nzene
026 1,3-dichlorobenzene
027 1,4-dichlorobenzene
028 3,3-dichlorobenzidine
029 1,1-dichloroethylene
0301,2-trans-dichloroethylene
031 2,4-d ich to ro pheno I
032 1, 2-dich loropropa ne
033 1,2-dichloropropylene (1,3-dichloropropene)
034 2,4-dimethyl phenol
035 2,4-dinitrotoluene
036 2,6-dinitrotoluene
037 1,2-diphenylhydrazine
038 Ethylbenzene
039 Fluoranthene
040 4-chlorophenyl phenyl ether
0414-bromophenyl phenyl ether
042 Bis(2-chloroisopropyl) ether
043 Bis(2-chloroethoxy) methane
044 Methylene chloride (dichloromethane)
045 Methyl chloride (dichloromethane)
046 Methyl bromide (bromomethane)
047 Bromoform (tribromomethane)
048 Dichlorobromomethane
051 Chlorodibromomethane
052 Hexachlorobutadiene
053 Hexachloromyclopentadiene
054 Isophorone
055 Naphthalene
056 Nitrobenzene
057 2-nitrophenol
058 4-nitrophenol
059 2,4-dinitrophenol
060 4,6-dinitro-o-cresol
061 N-nitrosodimethylamine
062 N-nitrosodiphenylamine
063 N-nitrosodi-n-propylamin
064 Pentachlorophenol
065 Phenol
066 Bis(2-ethylhexyl) phthalate
067 Butyl benzyl phthalate
068 Di-N-Butyl Phthalate
069 Di-n-octyl phthalate
070 Diethyl Phthalate
071 Dimethyi phthalate
0721,2-benzanthracene (benzo(a) anthracene
073 Benzo(a)pyrene (3,4-benzo-pyrene)
074 3,4-Benzofluoranthene (benzo(b) fluoranthene)
075 11,12-benzofiuoranthene (benzo(b) fluoranthene)
076 Chrysene
077 Acenaphthylene
078 Anthracene
079 1,12-benzoperylene (benzo(ghi) peryiene)
080 Fluorene
081 Phenanthrene
082 1,2,5,6-d ibenza nth race n e (dibenzo(,h) anthracene)
083 Indeno (,1,2,3-cd) pyrene (2,3-o-pheynyiene pyrene)
084 Pyrene
095 Tetrachioroethylene
086 Toluene
087 Trichloroethylene
088 Vinyl chloride (chloroethylene)
089 Aldrin
090 Dieldrin
091 Chlordane (technical mixture and metabolites)
092 4,4-DDT
093 4,4-DDE (p,p-DDX)
094 4,4-DDD (p,p-TDE)
095 Alpha-endosulfan
096 Beta-endosulfan
097 Endosulfan sulfate
098 Endrin
099 Endrin aldehyde
100 Heptachlor
101 Heptachlor epoxide (BHC-hexachlorocyclohexane)
102 Alpha-BHC
103 Beta-BHC
104 Gamma-BHC (lindane)
105 Delta-BHC (PCB -polychlorinated biphenyls)
106 PCB-1242 (Arochlor 1242)
107 PCB-1254 (Arochlor 1254)
108 PCB-1221 (Arochlor 1221)
109 PCB-1232 (Arochlor 1232)
110 PCB-1248 (Arochlor 1248)
111 PCB-1260 (Arochlor 1260)
112 PCB-1016 (Arochlor 1016)
113 Toxaphene
114 Antimony
116 Asbestos
117 Beryllium
125 Selenium
127 Thallium
129 2,3,7,8-tetrachloro-dibenzo-p-dioxin (TCDD)