January 23, 2017
Pretreatment Program – Reporting Requirements by Industrial Users (IUs)
POSTED BYShri Vani Sripada, E.I.T.
Demonstration of compliance requires certain Industrial Users (IUs) to submit and maintain reports. Since POTWs are responsible for receiving and analyzing reports including communicating applicable standards to IUs, these requirements are also important for POTWs.
In this blog, part of a series, I will talk about Categorical Industrial User (CIU) Reporting Requirements:
- Baseline Monitoring Report (BMR) (40 CFR 403.12(b)): This report must be submitted by IUs subject to categorical pretreatment standards within 180 days after the effective date of the standard or 180 days after the final administrative decision made concerning category determination, whichever is later. At a minimum, the report must contain description of operations, flow measurements, sampling and analysis results, categorical standards applicability, Certification by qualified professional and schedule for providing the additional operation and maintenance needed to comply with the pretreatment standards. New sources are required to submit the report at least 90 days before beginning the discharge excluding the certification and compliance schedule.
- Compliance Schedule Progress Report (40 CFR 403.12(c)(3)): CIUs unable to comply with the categorical standards are required to include a schedule as part of BMR, for attaining compliance with the standards. Schedules must include increments of progress in the form of dates for beginning and completion of major activities i.e., construction, plant process modification etc. The progress reports containing information on status of compliance schedule, any delays, and corresponding corrective actions are due to the POTW no later than 14 days following each date in the compliance schedule.
- 90-day Compliance Report (40 CFR 403.12(d)): Within 90 days of the compliance date specified in categorical regulation or 90 days of the date specified by the POTW, existing users must file a final compliance report. In case of new sources, it must be filed within 90 days of commencement of discharge to the POTW. The report must contain flow measurements, categorical pretreatment standards applicability, sampling analysis, etc. Reports must be certified by a qualified reviewing official and also signed and certified by authorized representative.
- Self-Monitoring Reports (40 CFR 403.12(e)): After the final compliance date or after starting to discharge into POTW for new sources, CIUs are required to submit self-monitoring reports to the POTW. These reports should contain information on nature and concentration of pollutants, flow data, mass of pollutants, production rates and other documentation required by POTW in a frequency as required by the city.
- Upset Reports (40 CFR 403.16): In case of unintentional and temporary non-compliance due to the factors beyond reasonable control of the CIU, CIUs are required to submit (at least) an oral report to the POTW within 24 hours and also must submit written report within 5 days. The report must contain: description of discharge, cause, date and time of non-compliance and corrective actions taken or planned to reduce, eliminate or prevent reoccurrence.
In my next blog, I will be talking about Reporting Requirements for Significant Industrial Users under the Pretreatment Program.
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.