December 30, 2016
Pretreatment Program – Reporting Requirements by POTW
POSTED BYShri Vani Sripada, E.I.T.
As we are heading into new year, this segment of my blog talks about the reporting required by the POTW for the coming year.
Under the Pretreatment Program (Program), POTWs are required to submit Annual Pretreatment Reports to the state (Kentucky Division of Water, for entities in Kentucky). The report documents the status and activities performed during the previous year and is due on March 1st of the following year.
Semi-annual reporting may be a required condition of the KPDES permit. Semi-annual reports must be submitted to the state by September 1st for the first half of the calendar year (i.e., January – June).
Below is the list of information that a report should contain at a minimum:
- A list of all the POTW’s industrial users (IUs) including name, address, type of industrial user, IU permit information, discharge information, and applicable federal standards.
- A summary of monitoring information along with non-compliance and enforcement actions, if any.
- A summary of pretreatment information including any changes to the POTW’s pretreatment program that have not been previously submitted to the state.
- An annual scan summary listing out the concentrations of effluent pollutants.
- Any other relevant information as requested by the state.
*Please note that this is just a base list and there may be additional documentation that needs to be submitted by the POTW if requested by the State. Kentucky has a Pretreatment Annual report form and it is available on their website.
These reports must be signed by a principal executive officer or ranking elected official or other duly authorized employee and the employee must be an individual or position having responsibility for the overall operation of the Pretreatment Program.
The state will review the overall performance of a POTW in monitoring industrial users, identifying violations and enforcing regulations. The performance of a POTW will be evaluated on the basis of POTW self-monitoring data, written Enforcement Response Plans (ERPs), audits, inspections, and pretreatment program reports. Hence, it is very important for a POTW to effectively manage program information to demonstrate proper implementation.
In my next blog, I will be talking on Reporting Requirements for Industrial Users under the Pretreatment Program.
Please contact me at mailto:firstname.lastname@example.org you have any questions.
I wish you a Merry Christmas and Happy New Year!
Shri Vani Sripada is a Project Engineer at Smith Management Group. Shri Vani can be reached at email@example.com
Source: Introduction to the National Pretreatment Program, U.S. EPA, Office of Wastewater Management, June 2011, 2016 Pretreatment Annual Report Form, KDOW.