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Recordkeeping requirements that must be followed by POTWs under the Pretreatment program.

Under the Pretreatment Program (Program), POTWs must maintain general program files documenting the City’s Pretreatment Program development and implementation activities and are required to maintain local limits records at least during the effective dates of the developed local limits and for 3 years after. Information should be readily accessible for inspection and copying by EPA and State representatives. As per 40 CFR 403.14, except for the confidential business information, all information submitted to the POTW or to the State must be available for the public without restriction.

 Below is the list of POTW records that must be retained:

  1. Sewer Use Ordinance;
  2. Program Procedures;
  3. Program approval and modifications;
  4. List of Significant Industrial Users (SIUs);
  5. Copy of POTW KPDES Permit;
  6. Local Limits development;
  7. Emergency Response Plan;
  8. Correspondence to and from EPA/State;
  9. Annual Reports to the State;
  10. Public Notices;
  11. Funding and resource changes;
  12. Applicable federal and State regulations;
  13. Industrial User (IU) compliance and permitting records;
  14. Industrial Waste Survey Results.

Below is the list of Industrial User Records that must be retained by POTW:

  1. Industrial Waste questionnaires;
  2. Permit Applications, permits and fact sheets;
  3. Inspection reports;
  4. IU Reports;
  5. Monitoring Data;
  6. Required plans i.e., slug control plan, sludge management, pollution prevention plan etc.;
  7. Enforcement Activities, if any;
  8. All correspondence to and from IUs including phone logs and meeting summaries.

*Please note that this is just a base list and there may be additional documentation that needs to be maintained by the POTW.

In my blog next month, I will discuss Reporting Requirements under the Pretreatment Program.

Please contact me if you have any questions.

Have a Happy Thanksgiving!

Shri Vani Sripada is a Project Engineer at Smith Management Group. Shri Vani can be reached at shrivani@smithmanage.com

Source: Introduction to the National Pretreatment Program, U.S. EPA, Office of Wastewater Management, June 2011.


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FEATURED PROJECT


PROBLEM

A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.


SMG'S APPROACH

SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.

SMG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.


RESULTS

SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.