HomeMy WebLinkAboutIndustrial Wastewater Permit - Honeywell International Inc.BOARD OF PUBLIC WORKS
AGENDA ITEM REVIEW REQUEST FORM
Date 10/12/2021
Name Serena Lozano-Shane Department: Utilities
BPW Date 10/26/2021 Phone Extension 5798
Review and Approval Required Prior to Submittal to Board Diversity Compliance
and Inclusion Officer Officer Name BPW Attorney Attorney Name
Dept. Attorney Attorney Name
Purchasing
Check the Appropriate Item Type – Required for All Submissions
Professional Services Agreement Contract Proposal
Open Market Contract Amendment/Addendum Special Purchase, QPA
Bid Opening Bid Award Req. to Advertise Title Sheet
Quote Opening Quote Award Reject Bids/Quotes
Proposal Opening C/O & PCA No. PCA
Chg. Order, No. Traffic Control Resolution
X Other: Industrial Permit Renewal: Honeywell International
Inc
Ease./Encroach
Required Information
Company or Vendor Name
New Vendor Yes If Yes, Approved by Purchasing
No
MBE/WBE Contractor MBE
WBE Completed E-Verify Form Attached Yes
No
Project Name
Project Number
Funding Source
Account No.
Amount
Terms of Contract
Purpose/Description ______________________________________________________________
______________________________________________________________
_____________________________________________________
For Change Orders Only
Amount of
Increase
Decrease
$
($ )
Previous Amount $
Current Percent of Change:
Increase
Decrease
%
( %)
New Amount $
Total Percent of Change:
Increase
Decrease
%
( %)
Time Extension Amount:
New Completion Date:
PERMIT BRIEFING MEMO
1. Facility Description
Honeywell International, Inc (Honeywell) engages in the manufacturing of wheels and brakes for
aircraft. The manufacturing of metal wheels and brakes involves grinding, pressing, cutting,
milling, drilling, deburring, etching, anodizing, shot-peening, washing, coating, painting, testing,
and assembly. The manufacture of carbon brakes involves pressure molding, carbon segment
needling, densification, machining, high temperature heat treating, testing, and assembly. Copper
linings were added to the South Bend process in 2021. No wastewater is produced from copper
linings which is the mixing, molding, and pressing copper linings for a variety of assembled parts
Honeywell manufactures. Honeywell also engages in the testing of aircraft fuel controllers and
fuel systems.
The manufacturing facility is spread throughout several major building groups and is
approximately 900,000 square feet. There are four main groups that have operations that occupy
the facility. The Wheels and Brakes Valve Stream (WBVS) uses South Bend as its base of OEM
operations, producing wheels and brakes for Commercial and Military customers. This operation
occupies Plants 3A, 4, 4A, 5, 12, 12A, 17, 21, 25, 35, and the Transportation Building. The main
operation includes a carbon fiber brake component factory and a metal/aluminum machining and
processing factory for structural wheel and brake components. Honeywell’s Engineering Test
Services (ETS) division occupies several Plants 3, 13, 14, 15, 15A, 19, and 32. For the testing of
Wheel and Brake components as well as Fuel Control modules that are designed in South Bend,
but manufactured in Rocky Mount, NC. There are a large number of engineers on site as part of
the mechanical Center of Excellent (MCOE) that reside in Plants 4B, 12, 12A, and 14. Finally,
Ground Support Solutions occupies Plant 26 and is a design, test, and building operation,
dedicated to hardware used to service Honeywell supplied components globally. Automotive is
now vacant, previously occupying plants identified as 1, 7, 9, 10, 23, 28, 31, 34, I-Beam, and 501,
accounting for approximately 422,000 square feet.
Plant operations are, in part, continuous, with approximately 500 employees. Building
construction ranges from 1944 with additions and upgrades through 2007 and operates 24/7 on 3
shifts.
2.Discharge Description
Honeywell has two permitted outfalls: Outfall 002 (407 MRS Wastewater Treatment Plant
System), and Outfall 005 (Zyglo Process).
Outfall 002 - Wastewater Treatment Plant - is located in plant 12A and is used to treat and
discharge batches of wastewater and does not discharge continuously. Wastewater discharged at
this outfall is subject to the Metal Finishing Categorical Pretreatment Standards. Therefore, the
more stringent of limits provided in either 40 CFR 433.15 or Chapter 17 of the City of South Bend
Municipal Code have been applied without modification. Non-categorical wastewater is never
commingled with categorical wastewater prior to discharge.
Discharge from Outfall 002 come from rinse waters from the Local Etch Line (LE) process,
Anodize Line tank dumps and rinse tank dumps, Belt Washer Wastewater, DI backwash, also
called regenerate, Nitric dialysis process, Sulfuric Dialysis Process. The DI units remove
impurities from the rinse waters so that the water may be reused.
NOTE: Honeywell has moved the discharge location of the non-categorical wastewater from the
regeneration of DI Units 1 and 2, to fifty (50) feet to the cast of Outfall #002. This discharge site is
1
Honeywell International Industrial Discharge Permit
dedicated to the discharge from these two units. Honeywell does not commingle or dilute
categorically regulated wastewaters with wastewaters from DI Units 1 and 2, since Units 1 and 2
purify City water and are subject to local limits only. Note, that the regenerate from DI Units 1
and 2 is stored in a dedicated tank until Honeywell’s internal testing results show that it meets
permit limits for discharge. By moving the discharge point from Outfall #002, Honeywell has
removed the potential for dilution of categorical waste. There is no monitoring requirement for the
DI regenerate from Units 1 and 2, as long as they purify City water only, since the mass of
pollutants in this water is the same as it would be if the water went directly from the tap to sewer.
Wastewater Treatment Plant pretreats the tank dumps, rinse tank dumps, nitric acid dialysis
process wastewater, belt washer wastewater, and sulfuric acid dialysis process wastewater, and
other miscellaneous wastewater, all of which may or may not be treated, as needed, to meet permit
limits. Wastewater from cleaning coolant reservoirs on machining centers, cleaning activities of
pits beneath machining centers, the belt washer, Dense Line and wastewaters from ETS’s salvage
pits which may contain jet fuel, may be treated by means of a microfiltration treatment system,
flow equalization, and grease and oil separation. Some waters from the Local Etch process and
the Anodize Line Rinse Tanks may go directly to the city sewer, unless Honeywell’s analysis of
the wastewater demonstrates a need for treatment. If treatment is required, the wastewater will be
transferred to the wastewater treatment plant for treatment to meet permit limits. Honeywell does
not commingle or dilute categorically regulated wastewaters with wastewater that is not
categorically regulated.
Outfall 005 is located on the Zyglo Line in Plant 12. Only wastewater from the Zyglo process is
discharged through Site 005. Wastewater discharged from this Outfall is subject to the Metal
Finishing Categorical Standards at 40 CFR 433.15. Therefore, the more stringent of limits found
in either the Metal Finishing Categorical Standards found at 40 CFR 433.15 or Chapter 17 of the
City of South Bend Municipal Code have been applied without modification. Zyglo, a fluorescent
dye penetrant, is sprayed on a part to be tested. The excess Zyglo material then drips into a
collection trough at the bottom of the spray chamber. The Zyglo material is then rinsed off at the
end of the process and that liquid drips into a collection trough at the bottom of that spray
chamber. Both troughs discharge through a 4-inch drain that is connected directly to the sewer.
Outfall 005 discharges continuously when the Zyglo Line is operating.
Discharge from Outfall #002 averages about 2400 gpd with a maximum of 6,000 gpd and Outfall
#005 averages 4760 gpd, with a maximum of 17,000 gpd.
3. Sample Site Description
Note: Pretreatment personnel will be escorted to all sampling sites by a Honeywell employee.
Sample Site # 002 is located in Plant 12A. Sample site # 002 is used to discharge batches of
wastewater and does not discharge continuously. Composite samples and grab samples will be
collected from the final drain pipe where wastewater is discharged to the sewer system. See
Figure 2 below.
Sample Site 005 is located in plant 12 and is incorporated into the Zyglo Station. Samples are
collected from a valve, i.e. sampling port, in the discharge line. Discharge is continuous through
Sample Site 005 when the Zyglo Line is operating. See Figure 6 below.
2
Honeywell International Industrial Discharge Permit
4.Wastewater Treatment
Outfall #002 – Wastewater Treatment Plant – treatment consists of chemical precipitation, flow
equalization, ion exchange, microfiltration, and pH adjustment. This process consists of batch
treatment.
Outfall #005 – Zyglo Process Line – wastewater is not pretreated prior to discharge.
5.Classification
Honeywell is classified as a B Categorical Industrial User (CIU) as defined in the South Bend
Municipal Code which states that all Categorical Industrial Users will be classified at a minimum
as a class B. Additionally, Honeywell is classified as a Metal Finisher covered by the Metal
Finishing Categorical Standards at 40 CFR 433.15 (PSES) due to the anodizing, etching, and
coating operations.
6.Calculation of Limits
Wastewater generally discharged at outfalls 002, and 005, are subject to the Metal Finishing
Categorical Standards at 40 CFR 433.15 and the more stringent of the limits provided in 40 CFR
433.15 or Chapter 17 of the City of South Bend Municipal Code have been applied without
modification. There is no need for modification to these limits because categorical and non-
categorical wastewaters are not commingled prior to or during discharge. Limits from the South
Bend Municipal Code will be applied to all non-categorical wastewaters.
7. Monitoring Frequency
Monitoring frequencies are based on South Bend’s US EPA approved Industrial Pretreatment
Program Monitoring Plan.
8.Industrial Operator Certification Requirement
Operator Certification Requirement: B
Industrial operator certification requirements are based on the criteria listed in Indiana
Administrative Code, Title 327, 5-22-4.
Permit Drafted by:
Industrial Pretreatment Group
City of South Bend
Division of Environmental Services
3
Honeywell International Industrial Discharge Permit
Figure 1. Outfall #002 and Sampling Site (Wastewater Treatment Plant)
Figure 6. 005 Outfall and sampling Site
Figure 2. 005 Outfall and sampling Site
Figure 2. 005 Outfall and sampling Site (Zyglo Line)
Sampling
Site 005
6
Honeywell International Industrial Discharge Permit
City of South Bend
Department of Public Works
Industrial Pretreatment Program
Significant Industrial User – Permit No. 160875-88358
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:
Honeywell International, Inc.
3520 Westmoor Street
South Bend IN 46628
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 9 August, 2021.
Effective on: 12 November, 2021
Expires on the: 11 November, 2026
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.
The permittee shall file an application for a renewal permit, a minimum of 90 days prior to the
expiration date.
Approved By:
October 26, 2021
7
Honeywell International Industrial Discharge Permit
CONTENTS
PART I
PART II
PART III
PART IV
ATTACHMENT 1
ATTACHMENT 2
ATTACHMENT 3
ATTACHMENT 4
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
REPORTING REQUIREMENTS
STANDARD CONDITIONS
DEFINITIONS
ENFORCEMENT RESPONSE PLAN
APPEALS PROCEDURE
TTO LIST
8
Honeywell International Industrial Discharge Permit
Facility Description
Honeywell International Inc. performs industrial manufacturing and testing of brake and wheel
components for aircraft and aircraft fuel actuation testing.
PART I – EFFLUENT LIMITATION
A. Sample Port and Collection Location
1. Sample Site Outfall #002 is located in Plant 12A. This sample site is used to
discharge batches of wastewater and does not discharge continuously. Composite
samples and grab samples are collected from the final discharge pipe.
Sample Site Outfall #005 is located in Plant 12 and is incorporated into the Zyglo
Station. Samples are collected from a valve, i.e. sampling port, in the discharge line.
Discharge is continuous through this sample site when Zyglo Line is operating.
2. 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 Outfall # 002 & #005:
Parameter Daily Maximum Limit (mg/L) Monthly Average Limit (mg/L)
Arsenic (mg/L) 1.0 0.3
Cadmium (mg/L) Report* Report*
Chromium (mg/L) 2.77 1.71
Copper (mg/L) 3.38 1.2
Cyanide (mg/L) 1.20 0.65
Lead (mg/L) Report* Report*
Mercury (mg/L) 0.00019 -na-
Nickel (mg/L) 3.98 0.8
Oil and grease (mg/l) 300 -na-
Oil and Grease TPH (mg/l) 100 -na-
Silver (mg/L) Report* Report*
TTO (mg/l) 2.13 -na-
Zinc (mg/L) 2.61 1.48
*Note: In accordance with the City of South Bend’s “What You Need Is What You Get” allocation method, local Daily Maximum
and Monthly Average limits have only been developed for those pollutants that have been observed at or above certain
concentrations in each Significant Industrial User’s wastewater discharge. If “Report” appears on the table, it has been determined
that an allocation of this pollutant is not necessary. The permittee shall compare any monitoring data for these pollutants with the
9
Honeywell International Industrial Discharge Permit
screening table in Part I (3) below. If pollutant concentrations above the screening levels are observed, a local Daily Maximum
and/or Monthly Average limit may be developed for that pollutant.
Please be aware that Federal Categorical Limits are still in effect, as required by 40 CFR 433 15. For pollutants that do not have
local limits in the table above, the permittee is still required to comply with any applicable categorical standards, below.
Parameter Daily Maximum (mg/L) Monthly Average Limit (mg/L)
Cadmium (mg/L)* 0.69 0.26
Lead (mg/L)* 0.69 0.43
Silver (mg/L)* 0.43 0.24
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 discrete or
composite sample collected, independent of the industrial flow rate and
the duration of the sampling event.
ii. 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 discrete 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.
b. 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.
10
Honeywell International Industrial Discharge Permit
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 Daily Maximum Screening Level (mg/L)
Arsenic (mg/L) 0.2
Cadmium (mg/L) 0.1
Chromium (mg/L) 2.0
Copper (mg/L) 0.3
Lead (mg/L) 0.3
Nickel (mg/L) 0.3
Silver (mg/L) 0.2
Zinc (mg/L) 0.3
11
Honeywell International Industrial Discharge Permit
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 sample sites #002 & #005:
Parameter Sampling Frequency Sampling Type
Arsenic (mg/L) Semiannual Composite
BOD5 (mg/L) Semiannual Composite
Cadmium (mg/L) Semiannual Composite
Cyanide (mg/L) Semiannual Grab
Lead (mg/L) Semiannual Composite
Silver (mg/L) Semiannual Composite
Mercury (mg/L) Semiannual Grab
Nickel (mg/L) Semiannual Composite
Oil and grease (mg/L) Semiannual Grab
Oil and Grease TPH (mg/L) Semiannual Grab
Phosphorus (mg/L) Semiannual Composite
TSS (mg/L) Semiannual Composite
TTO (mg/L) Semiannual Grab
pH (SU) Monthly Grab
Ammonia, nitrogen (mg/L) Monthly Composite
Chromium (mg/L) Monthly Composite
Copper (mg/L) Monthly Composite
Zinc (mg/L) Monthly Composite
Flow Monthly (gal) Monthly Continuously
Flow, total (gpd) Daily Continuously
See Flow Measurement Requirements referenced in Part III - Reporting Requirements.
12
Honeywell International Industrial Discharge Permit
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 the permittee demonstrates that time-proportional sampling is accurate
or as representative as flow-proportional sampling, then a time-proportional sample may be
collected.
a. If the permittee chooses to demonstrate that time-proportional sampling is accurate or as
representative as flow-proportional sampling, the permittee must submit a request, which
includes the certification statement found in Part III (A) (4) signed by the Authorized
Representative [see Part IV (B) (15)], within 120 days of the effective date of this permit
or they shall commence flow-proportional sampling at that time. Request to conduct
time-proportional sampling is subject to the Control Authority approval.
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. (Report due on the 20th of the following month)
5. Weekly monitoring frequency requires sampling to be conducted one (1) time in each calendar
week (Sunday to Saturday). (Report due on the 20th of the following month)
6. Monthly monitoring frequency requires sampling to be conducted a minimum of one (1) time
per calendar month. (Report due on the 20th of the following month)
7. Semiannual monitoring frequency requires sampling to be conducted a minimum of one (1) time
per semiannual period. (1st Semiannual Period: January to June [Report due on the 20th of July].
2nd Semiannual Period: July to December [Report due on the 20th of January])
8. Quarterly monitoring frequency requires sampling to be conducted a minimum of one (1) time
per calendar quarter. (1st Quarterly Period: January to March [Report due on the 20th of April].
2nd Quarterly Period: April to June [Report due on the 20th of July]. 3rd Quarterly Period: July
to September [Report due on the 20th of October]. 4th Quarterly Period: October to December
[Report due on the 20th of January])
13
Honeywell International Industrial Discharge Permit
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 >10 mg/L
Surcharge for Total Suspended Solids (TSS) >250 mg/L
C. Representative Sampling
1. 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
1. Monitoring results obtained shall be summarized and reported on an Industrial User Periodic
Compliance Report (PCR). The PCRs are due on the twentieth (20th) day 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
14
Honeywell International Industrial Discharge Permit
“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.”
b. If laboratory analytical data was not reported on the PCR, the requirement for the PCR
to be signed by a Certified Industrial Wastewater Operator is not required, unless
otherwise indicated by the Director.
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 (B)(15) of this
permit for 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. Please see Part IV B. 15. of this permit for
more information on designating a new 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.
15
Honeywell International Industrial Discharge Permit
C. Notification of Batch or Infrequent Discharge
1. 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 Pretreatment@SouthBendIN.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,
which shall include a description of the violation, the date and time the violation
occurred, and plan for investigating 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
1. 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
or report as to whether the existing plan is still being implemented shall be updated by the
30th of November on a continuous even two (2) year cycle (i.e. 2018, 2020, 2022...). 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.
16
Honeywell International Industrial Discharge Permit
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:
i. 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.
e. The plan shall also include the certification statement found in Part III (A) (4) signed by the
Authorized Representative [see Part IV (B) (15)]
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:
Imagineering Enterprises, Inc.
1302 West Sample Street
South Bend IN 46619-389
(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, and all compliance schedule 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.
The Certified Operator shall sign one of the following statements:
17
Honeywell International Industrial Discharge Permit
“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.”
Industrial Certified Operator Classification: B
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, and all compliance
schedule reports.
3. If a certified operator is not signing permittee’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.
4. If laboratory analytical data was not reported on the PCR, the requirement for the PCR to be
signed by a Certified Industrial Wastewater Operator is not required, unless otherwise indicated
by the Director.
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.
18
Honeywell International Industrial Discharge Permit
H. Flow Measurement Devices
1. The permittee shall submit a Flow Measurement Plan (FMP) within 90 days of the issuance of
this permit or report as to whether the existing plan is still being implemented. 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, and shall
include the certification statement found in Part III (A) (4) signed by the Authorized
Representative [see Part IV (B) (15)].
2. When internal process flow measurement is requested by the Director, the FMP shall also
describe how the flow of any internal processes will be measured. The FMP shall be subject to
review by the Control Authority.
3. 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.
4. The permittee shall calibrate any flow measurement device as needed and at least once every
twelve months. 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.
5. 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.
6. 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 due to a spill or slug to the sewer, or other
emergency, the permittee shall call 574-277-8515 and dial zero (0) to reach an operator.
19
Honeywell International Industrial Discharge Permit
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 (B) (15) of this permit,
complete contact information, and an effective date of this designation.
J. Total Toxic Organic (TTO) Requirements
1. Total Toxic Organics (TTO) is defined as the summation of all quantifiable values greater than
0.01 mg/L for the Toxic Organic Compounds (TOC) listed in 40 CFR 433.11 and in Attachment
4 of this permit. The following monitoring options are available for compliance with the TTO
semi-annual monitoring requirement. With each permit renewal at least two sampling events in
which all TOCs are sampled for and results reported must be completed prior to submitting a
request or TOMP as described below.
a. The permittee may monitor and report for all TTOs listed in Attachment 4, and at 40 CFR
433.11, at the frequency stated in this permit.
b. The permittee may request that monitoring be reduced to only those specific TOCs that
are expected to be present. To request a reduction in the number of compounds
monitored, the permittee shall complete two (2) monitoring events in which all TOCs are
sampled and reported. After completion of the second sampling event, the permittee may
request that monitoring be limited to only those compounds expected to be present, unless
additional compounds are identified through sampling.
c. The permittee may request to submit certification in lieu of monitoring for TTO at the
same frequency as TTO monitoring is required in this permit. To request that no
monitoring be required, the permittee shall complete two (2) monitoring events in which
all TOCs are sampled for and results reported. Upon completion of the two monitoring
events, and if no significant amounts of TOCs are identified, the permittee shall submit
a Toxic Organic Management Plan (TOMP) that is subject to review by the Control
Authority.
1. The TOMP shall include:
i. the toxic organic compound(s) used;
ii. the method of disposal used instead of discharging to the sewer, such as
reclamation, contract hauling, incineration, etc.;
iii. procedures for assuring that toxic organics do not spill or leak into wastewater;
and
20
Honeywell International Industrial Discharge Permit
2. Once the TOMP is accepted:
i. It shall be enforced as a part of this permit. Any deviation from the TOMP as
submitted shall constitute a permit violation.
ii. The permittee shall submit the following certification statement signed by the
permittee’s Authorized Representative at the same frequency as TTO
monitoring is required in Part II (A) of this Wastewater Discharge Permit. The
following certification statement shall be submitted in lieu of monitoring
results:
“Based on my inquiry of the person or persons directly responsible for
managing compliance with the Pretreatment Standard for total toxic
organics (TTO), I certify that, to the best of my knowledge and belief, no
dumping of concentrated toxic organics into the wastewaters has occurred
since filing the last discharge monitoring report. I further certify that this
facility is implementing the toxic organic management plan submitted to
the Control Authority.”
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 a fire 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.
21
Honeywell International Industrial Discharge Permit
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.
i. 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.
l. 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.
m. 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.
22
Honeywell International Industrial Discharge Permit
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.
r. 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.
23
Honeywell International Industrial Discharge Permit
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.
c. 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. Bypassing
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:
24
Honeywell International Industrial Discharge Permit
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
25
Honeywell International Industrial Discharge Permit
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 Enforcement
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 Plan
(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.
26
Honeywell International Industrial Discharge Permit
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 17-11(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, Subsection17-10(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.
27
Honeywell International Industrial Discharge Permit
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:
i. 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)(15) 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 which 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. Permittees 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
28
Honeywell International Industrial Discharge Permit
Management Practices established under Section 17-8 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.
29
Honeywell International Industrial Discharge Permit
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 superintendant, 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.
iii. 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 (B) (15) of this permit,
complete contact information, and an effective date of this designation.
30
Honeywell International Industrial Discharge Permit
ATTACHMENT 1:
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: Director means the Director of Utilities of the City of South Bend, Indiana, or the Director's 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.
Industrial wastes: means any solid, liquid or gaseous substances or form of energy discharged, permitted to flow
or escape from an industrial, manufacturing, commercial or business process or from the development, recovery
or processing of any natural resource carried on by a permittee or a person, and shall further mean any
nondomestic waste to a City sewer system.
Slug (or slug load): 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.
31
Honeywell International Industrial Discharge Permit
Attachment 2:
ENFORCEMENT
RESPONSE
PLAN
CITY OF SOUTH BEND
INDUSTRIAL PRETREATMENT
32
Honeywell International Industrial Discharge Permit
Enforcement Response Plan Outline
I. Management Plan
A. Permit Application and Classification
B. Permitting
C. Monitoring
D. Field Inspection and Analysis
E. Compliance Decisions and Enforcement
II. Enforcement Procedures
III. 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
This Enforcement Response Plan was written with the guidance of U.S. EPA document PB90-185083,
Guidance for Developing Control Authority Enforcement Response Plans. 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
33
Honeywell International Industrial Discharge Permit
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 with recommendations from the Director of Environmental Services.
The following information describes in more detail the 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.IUs 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 5% of the POTW’s dry weather hydraulic or
organic loading capacity.- SIU
4.IUs that have a reasonable potential to adversely affect POTW 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. Permitting
The pretreatment staff assesses the 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.
34
Honeywell International Industrial Discharge Permit
C. Monitoring
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.
D. 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.
35
Honeywell International Industrial Discharge Permit
The Enforcement Response Plan groups various types of violations into the following four categories:
1. 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 the 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 the 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 other Pretreatment Standard or Requirement, or that the
User's 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 may be 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 the 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,
36
Honeywell International Industrial Discharge Permit
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 the 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 other Pretreatment Standard or Requirement, the 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-
monitoring and management practices designed to minimize the amount of pollutants
discharged to the sewer. A compliance order may not extend the deadline for compliance
established for 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:
37
Honeywell International Industrial Discharge Permit
(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 403.3(l);
(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 the 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 of POTW 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 ninety (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;
(f) 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 the 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, the events from the previous quarter may be used in
determining SNC in the following period.
38
Honeywell International Industrial Discharge Permit
IV. Enforcement Response Plan Examples
A. Sampling, Monitoring, and Reporting
Non-Compliance Circumstances Range of Response
Failure to sample, monitor
or report Isolated, or infrequent
LOV requiring correction within 14
days, AF, AO
Failure to sample, monitor,
report, and notify Control
Authority Isolated or infrequent
LOV requiring correction within 14
days, Escalated AF, AO
Failure to sample, monitor,
report, and notify Control
Authority
Frequent, or IU does not respond to
LOV LOV, AF, AO, SNC
Failure to notify of effluent
limit violation, or slug
discharge
Isolated, or infrequent. No known
effects.
LOV, AF, AO if no response within 14
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
discharge
Known environmental or POTW
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
Non-Compliance Circumstances Range of Response
Exceeding Final Limits
(categorical, local, or
prohibited) Infrequent or isolated minor violation LOV, AF
Exceeding Final Limits
Infrequent or isolated major violations,
exceed TRC limits
LOV & AF, AO, LIT if environmental
harm results
Exceeding Final Limits Violation(s) which are SNC AF, AO, LIT
Exceeding Interim Limits No known damages LOV, AF, AO
Exceeding Interim Limits
Results in known environmental or
POTW damage - SNC LOV, AF, AO, LIT
Reported Slug load Isolated, no known damage LOV, Show cause, AF, AO
Reported Slug load
Isolated with known interference, pass
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 approval One time, results in damage
LOV,AF, AO, LIT, or request for
criminal investigation
Discharge without permit
or approval
Continuing violation with known
damage
LIT, request for criminal investigation,
sewer disconnect
39
Honeywell International Industrial Discharge Permit
C. Non-compliance detected through inspections or field investigation
Non-Compliance Circumstances Range of Response
Minor violation of
analytical procedures Any instance LOV, AF with continuing violation
Major violation of
analytical procedures No evidence of intent LOV, AF, AO
Major violation of
analytical procedures Evidence of negligence or intent - SNC
LOV, AF, AO, LIT (possible criminal
action)
Minor violation of permit
condition No evidence of negligence or intent
LOV, immediate corrective action
required, AF
Minor violation of permit
condition Evidence of negligence or intent - SNC
AF, AO, SNC, LIT (possible criminal
action)
Major violation of permit
condition Evidence of negligence or intent - SNC
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
Missed interim date
Will not cause late final or other
interim date LOV
Missed interim date
Will result in other missed interim
dates, violation for valid cause LOV, AO
Missed interim date
Will result in other missed interim
dates, no valid cause - SNC LOV, AO, LIT
Missed final date
90 days or more, failure or refusal to
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 up 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 environmental 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.
40
Honeywell International Industrial Discharge Permit
ATTACHMENT 3:
Appeals Procedure
Any permittee desiring to dispute a fine must file a written request for the Director to reconsider the fine within ten
(10) days of being notified of the fine. Where a request has merit, the Director may convene a hearing on the matter.
In the event the permittee’s appeal is successful, the Director may reconsider to waive or reduce the fine. The
Director may add the costs of preparing administrative enforcement actions, such as notices and orders, to the fine.
Any User aggrieved by a final action of the Director requiring a permittee to restrict the volume or point of discharge;
requiring a permittee to install a storage or flow-control facility; denying a permit transfer; revoking a permit; or
issuing any authorized Administrative Enforcement Remedy, may request reconsideration by the Director within
fifteen (15) days of such Director action, and the Director shall have thirty (30) days from receipt of request to make
a decision related to reconsideration.
An administrative appeal from any terms of an individual wastewater discharge permit shall be made as described
in the paragraph above, but the effectiveness of the individual wastewater discharge permit shall not be stayed
pending the administrative appeal.
Appeals to the Director shall be submitted to:
Director of Public Utilities
3113 Riverside Drive
South Bend, IN 46628
If the ruling made by the Director is unsatisfactory to the person requesting reconsideration, or if the Director fails
to act within thirty (30) days from receipt of the request, the permittee may, within seven (7) days after notification
of action, or if the Director fails to act, within thirty-five (35) days of the date of request for Director reconsideration,
file a written appeal to the Board of Public Works. The written appeal shall be heard by the Board within thirty
(30) days from the date of filing. The Board of Public Works shall make a final ruling on the appeal within thirty
(30) days of the close of the meeting. The Director's decision, action, or determination shall remain in effect during
such period of reconsideration and appeal. Appeals to the Board of Public Works shall be submitted to:
Board of Public Works
1316 County City Building
227 W. Jefferson Blvd
South Bend, IN 46601
All appeals shall carbon copy (cc) the City of South Bend’s Pretreatment Coordinator(s).
For clarification or additional details about the appeals procedure see the City of South Bend Ordinance Sections
17-10 & 17-11.
41
Honeywell International Industrial Discharge Permit
ATTACHMENT 4:
TOTAL TOXIC ORGANICS LIST
Acenaphthene 3,3-dichlorobenzidine
Acrolein 1,1-dichloroethylene
Acrylonitrile 1,2-trans-dichloroethylene
Benzene 2,4-dichlorophenol
Benzidine 1,2-dichloropropane
Carbon tetrachloride
(tetrachloromethane)
1,3-dichloropropylene (1,3-
dichloropropene)
Chlorobenzene 2,4-dimethylphenol
1,2,4-trichlorobenzene 2,4-dinitrotoluene
Hexachlorobenzene 2,6-dinitrotoluene
1,2-dichloroethane 1,2-diphenylhydrazine
1,1,1-trichloroethane Ethylbenzene
Hexachloroethane Fluoranthene
1,1-dichloroethane 4-chlorophenyl phenyl ether
1,1,2-trichloroethane 4-bromophenyl phenyl ether
1,1,2,2-tetrachloroethane Bis (2-chloroisopropyl) ether
Chloroethane Bis (2-chloroethoxy) methane
Bis (2-chloroethyl) ether Methylene chloride (dichloromethane)
2-chloroethyl vinyl ether (mixed) Methyl chloride (chloromethane)
2-chloronaphthalene Methyl bromide (bromomethane)
42
Honeywell International Industrial Discharge Permit
2,4,6-trichlorophenol Bromoform (tribromomethane)
Parachlorometa cresol Dichlorobromomethane
Chloroform (trichloromethane) Chlorodibromomethane
2-chlorophenol Hexachlorobutadiene
1,2-dichlorobenzene Hexachlorocyclopentadiene
1,3-dichlorobenzene Isophorone
1,4-dichlorobenzene Naphthalene
Nitrobenzene 1,12-benzoperylene
2-nitrophenol (benzo(ghi)perylene)
4-nitrophenol Fluorene
2,4-dinitrophenol Phenanthrene
4,6-dinitro-o-cresol 1,2,5,6-dibenzanthracene
N-nitrosodimethylamine (dibenzo(a,h)anthracene)
N-nitrosodiphenylamine Indeno (1,2,3-cd) pyrene)
N-nitrosodi-n-propylamine (2,3-o-phenylene pyrene)
Pentachlorophenol Pyrene
Phenol Tetrachloroethylene
Bis (2-ethylhexyl) phthalate Toluene
Butyl benzyl phthalate Trichloroethylene
Di-n-butyl phthalate Vinyl chloride (chloroethylene)
Di-n-octyl phthalate Aldrin
43
Honeywell International Industrial Discharge Permit
Diethyl phthalate Dieldrin
Dimethyl phthalate 4,4-DDT
1,2-benzanthracene 4,4-DDE (p,p-DDX)
(benzo(a)anthracene) 4,4-DDD (p,p-TDE)
Benzo(a)pyrene (3,4-benzopyrene) Alpha-endosulfan
3,4-Benzofluoranthene Beta-endosulfan
(benzo(b)fluoranthene) Endosulfan sulfate
11,12-benzofluoranthene Endrin
(benzo(k)fluoranthene) Endrin aldehyde
Chrysene Heptachlor
Acenaphthylene Heptachlor epoxide
Anthracene 2,3,7,8-tetrachlorodibenzo-
(BHC-hexachlorocyclohexane) p-dioxin (TCDD)
Alpha-BHC Gamma-BHC
Beta-BHC Delta-BHC
(PCB-polychlorinated biphenyls) PCB-1016 (Arochlor 1016)
PCB-1221 (Arochlor 1221) PCB-1232 (Arochlor 1232)
PCB-1242 (Arochlor 1242) PCB-1248 (Arochlor 1248)
PCB-1254 (Arochlor 1254) PCB-1260 (Arochlor 1260)
Toxaphene
Chlordane (technical mixture and
metabolites)