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REPORTING REQUIREMENTS – INDUSTRIAL USERS
WRITTEN BYShri Vani Sripada, E.I.T.
In my previous blog post, I talked specifically about Categorical Industrial User (CIU) Reporting Requirements and schedule for reporting. In continuation of that, this blog entry focuses upon the Reporting Requirements for all Significant Industrial Users (SIUs).
Periodic Compliance Report (40 CFR 403.12(h)): The Periodic Compliance Report must be submitted by SIUs at least once every 6 months on dates specified by POTW describing the nature and concentration of pollutants, flow and any additional information required by the POTW. SIUs provide this report to POTWs with their current information regarding pollutants that are being discharged to the treatment plant. In the case of larger industrial users or industries that have more potential to violate set standards, requirements would ask for more frequent sampling and reporting, as required by the POTW.
Notifications applicable to all Industrial Users (IUs)
Slug Control Plan (40 CFR 403.8(f)(2)(vi)): As defined under the regulation, “Slug discharge is any discharge of non-routine, episodic nature including an accidental spill or non-customary batch discharge that has reasonable potential to cause interference or pass through or in any other way violate the POTW’s regulations, local limits or permit conditions.” SIUs must be evaluated within 1 year of designation by the POTW. SIUs must submit a plan if a POTW determines that a plan is needed. If a slug discharge is identified by the SIU, POTW must be notified immediately after occurrence.
Bypass Report (40 CFR 403.17): As defined in the regulation, “Bypass is an intentional diversion of wastestream from any portion of an IU’s treatment facility.” At least 10 days before the date of the planned bypass, IU must submit notice to the POTW. If there is an unanticipated bypass, IU must provide oral notice within 24 hours from the time IU becomes aware of the bypass followed by a written notification within 5 days.
Additional Notifications for all IUs:
- IU must notify in advance of any substantial change in the volume or character of the pollutant.
- IU must immediately notify of any discharge that could cause potential problems to POTW.
- IU must notify POTW within 24 hours of becoming aware of a violation and must repeat sampling within 30 days of the original violation and report it to POTW.
Recordkeeping: IUs are required to maintain monitoring and compliance records for at least 3 years.
Please note that there can be additional notifications as required by the POTW.
In my next blog, I will be talking about the control programs for determining the nature of hauled waste to the POTW.
Please contact me if you have any questions. Shri Vani Sripada is a Project Engineer at Smith Management Group. Shri Vani can be reached at firstname.lastname@example.org
Source: Introduction to the National Pretreatment Program, U.S. EPA, Office of Wastewater Management, June 2011.
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 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.
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.