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Home My WebLink AboutPAR 2023PAR Workshop 2023 Presented by: Division of Water Resources NPDES Municipal Permitting Unit - Pretreatment Compliance Judgment,SNC, and PARs What Do I Do? February 8th, 2024 Learn about and refresh yourself on: •How to Judge SIU Compliance •When are Industries Really Bad •What needs to be in the PAR •How to Fill Out All Those Forms •Who, What, and Where to Publish •What DWR Wants to See in a Narrative Compliance Judgment, SNC, and PAR Workshop Introduction to the Basics of Judging Compliance, Dealing with SNC, and Compiling Annual Reports 2 Today’s Outline 1. Introduction-NPDES Requirement 2. Compliance Judgment •SNC Definition •SNC for Reporting/Permit Conditions •SNC for Limits Violations •Data Summary Form •Compliance Judgment Examples Compliance Judgment, SNC, and PAR Workshop Introduction to the Basics of Judging Compliance, Dealing with SNC, and Compiling Annual Reports 3 Compliance Judgment, SNC, and PAR Workshop Introduction to the Basics of Judging Compliance, Dealing with SNC, and Compiling Annual Reports Today’s Outline (cont.) 3. IDSF 4. SNCR Form 5. PPS Form 6. Narrative 7. Waste Reduction 8. Public Notice 9. Enforceable Compliance Schedules (Orders) 10. Allocation Table 4 Introduction -NPDES Requirements PART IV (from NPDES Permit) OTHER REQUIREMENTS D. Pretreatment Program Requirements 10. Pretreatment Annual Reports (PAR) The permittee shall report to the Division in accordance with 15 A NCAC 2 H .0908 (b) In lieu of submitting annual reports, Modified Pretreatment Programs may be required to meet with Division personnel periodically to discuss the enforcement of pretreatment requirements and other pretreatment implementation issues, 15A NCAC 2H .0908(c). For all other active pretreatment programs, the permittee shall submit two copies of a Pretreatment Annual Report (PAR) describing its pretreatment activities over the previous twelve months to the Division at the following address : NC DENR / Division of Water Resources NPDES Municipal Unit / Pretreatment 1617 Mail Service Center RALEIGH, NC 27699-1617 5 Introduction -NPDES Requirements (cont.) These reports shall be submitted by March 1 of each year and shall contain the following: a.) Narrative A narrative summary detailing actions taken, or proposed, by the Permittee to correct significant non-compliance and to ensure compliance with pretreatment requirements; b.) Pretreatment Program Summary (PPS) A pretreatment program summary (PPS) on forms or in a format provided by the Division; c.)Significant Non-Compliance Report (SNCR) A list of Industrial Users (IUs) in significant noncompliance (SNC) with pretreatment requirements, and the nature of the violations on forms or in a format provided by the Division. Note, for the 2023 PAR no SNC historical data will be provided by DWR; 6 Introduction -NPDES Requirements (cont.) d.) Industrial Data Summary Forms (IDSF) Monitoring data from samples collected by both the POTW and the Significant Industrial Users (SIUs). These analytical results must be reported on Industrial Data Summary Forms (IDSF) or on other forms or in a format provided by the Division ; e.) Other Information Copies of the POTW's allocation table, new or modified enforcement compliance schedules, public notice of IUs in SNC, a summary of data or other information related to significant noncompliance determinations for IUs that are not considered SIUs, and any other information, upon request, which in the opinion of the Director is needed to determine compliance with the pretreatment implementation requirements of this permit; 7 Introduction – NC Pretreatment Rules [North Carolina Administrative Code (NCAC)] 8 Introduction – NC Pretreatment Rules •from 15A NCAC 2H .0908(b) • Control Authorities with active approved pretreatment programs shall submit once per year a pretreatment report describing its pretreatment activities over the previous 12 months. Two copies of each pretreatment report shall be submitted to the Division by March 1 of each year for activities conducted for two six -month periods, January 1 through June 30 and July 1 through December 31 of the previous year. This annual report shall contain the following information in accordance with forms specified by the Division: •(1) a narrative summary of actions taken by the control authority to ensure compliance with pretreatment requirements; •(2) a pretreatment program summary on forms or in a format provided by the Division; 9 Introduction - NC Pretreatment Rules (cont.) •from 15A NCAC 2H .0908(b) (cont.) •(3) A list of industrial users in significant noncompliance with pretreatment requirements, the nature of the violations, and actions taken or proposed to correct the violations; on forms or in a format provided by the Division; •(4) An allocation table as described in Rule .0916(c)(4) listing permit information for all significant industrial users, including but not limited to permit limits, permit effective and expiration dates, and a comparison of total permitted flows and loads with Division approved maximum allowable loadings of the POTW, including flow, on forms or in a format provided by the Division; 10 Introduction - NC Pretreatment Rules (cont.) •from 15A NCAC 2H .0908(b) (cont.) •(5) Other information which in the opinion of the Division Director is needed to determine compliance with the implementation of the pretreatment program, including, but not limited to, significant industrial user compliance schedules, public notice of industrial users in significant noncompliance, a summary of significant industrial user effluent monitoring data as described in Paragraphs (a) and (e) of this Rule, a summary of information related to significant non - compliance determination for industrial users that are not considered significant industrial users, and Long or Short Term Monitoring Plan data on forms or in a format provided by the Division; 11 Introduction - NC Pretreatment Rules (cont.) •40 CFR 403.12(i) Annual POTW reports (1)Updated list of SIUs (AT) (2)Compliance status (SNCR) (3)Summary of enforcement activities (PPS & narrative) (4)Summary of program changes (narrative & program info sheet) (5)Any other relevant information 12 Compliance Judgment 13 Compliance Judgment Detection of Violations of ALL Types: 1. Limits 2. Reporting 3. Permit Conditions References: •DWR Approved Enforcement Response Plan (ERP) for Your POTW •Comprehensive Guide, Chapter 7, Compliance & Inspection, Sections D and E •Comprehensive Guide, Chapter 8, Enforcement •Pretreatment’s Annual Report web-site files “So your SIU has a limits violation-What do you do?” and “So your SIU has a reporting violation -What do you do?” 14 Compliance Judgment – What must be done •POTW must identify all violations in a timely fashion as outlined in your ERP (preferably monthly). •POTW must issue a Notice of Violation (NOV) for all violations. •Significant Noncompliance (SNC) is the way to separate out the more significant violations for escalated enforcement action. 15 Compliance Judgment - What must be done (cont.) •POTW must do an SNC determination at a minimum of every six months. •It is strongly recommended that a preliminary SNC determination be done halfway through the six -month period, especially where there was SNC in the previous period. •The SNC determination must be within 30 days of receiving all the data for that period. •SNC determination and follow-up enforcement action for the January through June reporting period should be completed no later than September 1st of that same year. •SNC Determination and follow-up enforcement action for the July through December reporting period should be completed no later than March 1st of the following year. 16 Compliance Judgment - What must be done (cont.) Repeat SNCs •Repeat SNCs are a serious matter. •If an Industry will be in SNC for a second consecutive period for the same parameter or requirement, the Division and EPA expect the POTW to take “appropriate action.” •The typical choices for “appropriate action” are: 1.modify permit 2.place SIU on an enforceable compliance schedule (compliance schedule with stipulated penalties) 3.SIU ceases discharge (on their own or by order of POTW) 4.SIU dropped from POTW’s list of SIUs 17 Compliance Judgment - What must be done (cont.) Repeat SNCs (cont.) •The POTW should make every effort to take the “appropriate action” before the end of the second consecutive SNC Period. •In those special cases where this is not possible, take the “appropriate action” within two months after the end of that second period. If this is not done, the Division may take enforcement action against the POTW for failure to take adequate enforcement. •Call DWR to discuss extenuating circumstances 18 SNC Definition 19 SNC Definition Significant Noncompliance is defined by 15A NCAC 2H .0903(b)(31) and Section 1.2(a)(35) of the NC Model Sewer Use Ordinance (SUO) as follows: “Significant Noncompliance” or “SNC” is the status of noncompliance of a significant industrial user when one or more of the following criteria are met:…. 20 SNC Definition (cont.) (A) “Chronic violations” of wastewater discharge limits, defined here as those in which sixty-six percent or more of all the measurements taken for the same pollutant parameter (not including flow) during a six-month period exceed (by any magnitude) a numeric pretreatment standard or requirement including instantaneous limits, as defined by 40 CFR Part 403.3(l); Chronic SNC is when 66% or more are > limit! 21 SNC Definition (cont.) (B) “Technical Review Criteria” (TRC) violations, defined here as those in which thirty-three percent or more of the measurements taken for the same pollutant parameter (not including flow) during a six-month period equal or exceed the product of the numeric pretreatment standard or requirement, including instantaneous limits, as defined by 40 CFR 403.3(l) multiplied by the applicable TRC; (TRC = 1.4 for BOD, TSS, fats, oil and grease, 1.2 for all other pollutants (except flow and pH)); TRC SNC is when 33% or more are > or = TRC value! 22 SNC Definition (continued) (C) Any other violation of a pretreatment standard or requirement as defined by 40 CFR 403.3(l) (daily maximum, long-term average, instantaneous limit, or narrative standard) that the control authority (or POTW, if different from the control authority) 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 or wastewater that has caused imminent endangerment to human health, welfare or to the environment or has resulted in either the control authority’s or the POTW’s, if different than the control authority, exercise of its emergency authority under 40 CFR Part 403.8(f)(1)(vi)(B) to halt or prevent such a discharge; 23 SNC Definition (continued) (E)Failure to meet, within 90 days after the schedule date, a compliance schedule milestone contained in a pretreatment permit or enforcement order for starting construction, completing construction, or attaining final compliance; (F)Failure to provide, within 45 days after the due date, required reports such as baseline monitoring reports, 90-day compliance reports, self-monitoring reports, and reports on compliance with compliance schedules; (G)Failure to accurately report noncompliance; (H) Any other violation or group of violations that the control authority or POTW determines will adversely affect the operation or implementation of the local pretreatment program. 24 Compliance Judgment for Reporting (includes permit condition) Applies to any kind of report or notification: • Failure to collect self-monitoring samples • Failure to submit reports or follow permit conditions. Includes reports being late or incomplete as well as a complete failure to submit a report or follow IUP condition at all. Types of reports include but are not limited to: ✓sample results ✓flow monitoring reports ✓24-hour notification ✓resample and submit results within 30 days ✓properly operate pretreatment units ✓change in process ✓obtain authorization to Construct ✓file application for IUP renewal ✓sludge management plans ✓slug/spill plans ✓TTO certification ✓TOMP compliance assessment 25 SNC For Reporting/Permit Conditions (cont.) POTW Prerogative: H)Any other violation or group of violations that the control authority or POTW determines will adversely affect the operation or implementation of the local pretreatment program. 26 SNC For Reporting/Permit Conditions (cont.) •To be completed on a Six-Month Basis, but really applies to each report Examples: 1) An Industry is required by their IUP to sample monthly for 10 parameters and report the results to the POTW by the 20th day of the month following the month in which the samples were collected. The results of the samples collected in July, due August 20, are not received until October 23. 27 SNC For Reporting/Permit Conditions (cont.) 2) Industry fails to collect the required samples in November at all. 3) An Industry is required by their IUP to re-apply by February 1 (180 days before the IUP expires on August 1) and the application is not received until May 15. Call Pretreatment Staff to discuss any extenuating circumstances See PAR Guidance for discussion and some examples of extenuating circumstances 28 SNC for Limits Violations For any typical violations, the POTW must make a determination based on the following categories that may elevate a violation to SNC: SNC for Limits Categories a)Pass -through/Interference b)Threat to Human Health, Welfare or the Environment c)Emergency Suspension from such a Discharge *The POTW must provide evidence to justify making this determination. 29 SNC for Limits Violations SNC for Limits Categories (cont.) d)Chronic Violations (those that exceed limit by any quantity) •66% or more of all measurements during the 6 -month period. e)Technical Review Criteria (TRC) Violations (those that equal or exceed a TRC adjusted limit by any quantity) •Limit * 1.4 for BOD, TSS, fats, oils, and grease •Limit * 1.2 for all other parameters, except pH •33% or more of all measurements during the 6 -month period. 30 SNC for Limits Violations SNC for Limits Categories (cont.) H)Any other violation or group of violations that the control authority or POTW determines will adversely affect the operation or implementation of the local pretreatment program. 31 SNC for Limits Violations (continued) Completed on a Six Month Basis Calculated For Each Limit For Example: An Industry has both a daily maximum concentration limit as well as a monthly average concentration limit for BOD. At the end of the six -month period, when calculating SNC for the parameter of BOD, you judge SNC for BOD separately for the daily max and the monthly average limits. 32 SNC for Limits Violations (continued) Forms Used For SNC •Industrial Data Summary Forms (IDSF) or other forms or in a format provided by the Division; •Compliance Judgment Worksheet (Ch. 7, North Carolina Comprehensive Guidance for Pretreatment Programs) Other •SNC for pH (no TRC required) •SNC for Flow (flow is not a “pollutant”) Call Pretreatment Staff to discuss extenuating circumstances See PAR Guidance for discussion of SNC for pH, flow, and some examples of extenuating circumstances. 33 Data Summary Form FLOW BOD TSS AMMONIA ARSENIC Sample Date POTW or SIU Sample MGD <mg/L <mg/L <mg/L 7/17/12 SIU 0.0752 7/24/12 POTW 0.0469 8/7/12 SIU 0.0313 8/23/12 SIU 0.0538 9/3/12 SIU 0.079 10/9/12 SIU 0.0676 10/21/12 SIU 0.0681 11/1/12 SIU 0.0657 11/16/12 SIU 0.0678 12/11/12 SIU 0.0292 Column Averages =>0.0585 Maximum 0.0790 Minimum 0.0292 Sample Location: Will Plateit Spreadsheet Instructions: 1) Data entered only in Heavy Bordered cells. Rest of worksheet is protected, password is "2". 2) For below detection data, enter "<" in "<" column, and enter detection level in Influent or Effluent mg/l columns. Spreadsheet will auto - matically calculate averages and removal rates using 1/2 value entered. 34 Data Summary Form FLOW ARSENIC CADMIUM CHROMIUM COPPER Sample Date POTW or SIU Sample MGD <mg/L <mg/L <mg/L 7/17/12 SIU 0.0752 0.042 0.042 0.0263 0.32 0.315 0.1976 7/24/12 POTW 0.0469 0.086 0.086 0.0336 0.53 0.532 0.2081 8/7/12 SIU 0.0313 0.087 0.087 0.0227 0.37 0.373 0.0974 8/23/12 SIU 0.0538 0.077 0.077 0.0345 9/3/12 SIU 0.079 0.067 0.067 0.0441 0.82 0.818 0.5389 10/9/12 SIU 0.0676 0.089 0.089 0.0502 0.23 0.231 0.1302 10/21/12 SIU 0.0681 0.076 0.076 0.0432 11/1/12 SIU 0.0657 0.091 0.091 0.0499 0.21 0.206 0.1129 11/16/12 SIU 0.0678 0.069 0.069 0.0390 12/11/12 SIU 0.0292 0.057 0.057 0.0139 0.72 0.721 0.1756 Column Averages =>0.0585 0.0741 0.0357 0.4566 0.2087 Maximum 0.0790 0.0910 0.0502 0.8180 0.5389 Minimum 0.0292 0.0420 0.0139 0.2060 0.0974 Sample Location: Will Plateit 35 Data Summary Form FLOW COPPER CYANIDE LEAD MERCURY Sample Date POTW or SIU Sample MGD <mg/L <mg/L <mg/L 7/17/12 SIU 0.0752 1.71 1.713 1.0743 <0.01 0.005 0.0031 0.02 0.02 0.0125 7/24/12 POTW 0.0469 1.12 1.121 0.4385 <0.01 0.005 0.0020 0.10 0.1 0.0391 8/7/12 SIU 0.0313 1.32 1.321 0.3448 <0.01 0.005 0.0013 0.03 0.03 0.0078 8/23/12 SIU 0.0538 9/3/12 SIU 0.079 0.86 0.862 0.5679 <0.01 0.005 0.0033 <0.01 0.005 0.0033 10/9/12 SIU 0.0676 0.78 0.781 0.4403 <0.01 0.005 0.0028 0.01 0.01 0.0056 10/21/12 SIU 0.0681 11/1/12 SIU 0.0657 0.93 0.927 0.5079 <0.01 0.005 0.0027 0.09 0.09 0.0493 11/16/12 SIU 0.0678 12/11/12 SIU 0.0292 1.53 1.531 0.3728 <0.01 0.005 0.0012 0.07 0.07 0.0170 Column Averages =>0.0585 1.1794 0.5352 0.0050 0.0024 0.0464 0.0193 Maximum 0.0790 1.7130 1.0743 0.0050 0.0033 0.1000 0.0493 Minimum 0.0292 0.7810 0.3448 0.0050 0.0012 0.0050 0.0033 Sample Location: Will Plateit 36 Data Summary Form FLOW MERCURY MOLYBDENUM NICKEL SELENIUM Sample Date POTW or SIU Sample MGD <mg/L <mg/L <mg/L 7/17/12 SIU 0.0752 <0.0002 0.0001 0.00006 1.98 1.98 1.2418 7/24/12 POTW 0.0469 <0.0002 0.0001 0.00004 1.64 1.64 0.6415 8/7/12 SIU 0.0313 <0.0002 0.0001 0.00003 2.86 2.86 0.7466 8/23/12 SIU 0.0538 2.02 2.02 0.9064 9/3/12 SIU 0.079 <0.0002 0.0001 0.00007 1.72 1.72 1.1332 10/9/12 SIU 0.0676 <0.0002 0.0001 0.00006 3.03 3.03 1.7083 10/21/12 SIU 0.0681 2.52 2.52 1.4312 11/1/12 SIU 0.0657 <0.0002 0.0001 0.00005 2.38 2.38 1.3041 11/16/12 SIU 0.0678 1.57 1.57 0.8878 12/11/12 SIU 0.0292 <0.0002 0.0001 0.00002 1.79 1.79 0.4359 Column Averages =>0.0585 0.000100 0.000047 2.1510 1.0437 Maximum 0.0790 0.000100 0.000066 3.0300 1.7083 Minimum 0.0292 0.000100 0.000024 1.5700 0.4359 Sample Location: Will Plateit 37 Data Summary Form FLOW SELENIUM SILVER ZINC OIL & GREASE Sample Date POTW or SIU Sample MGD <mg/L <mg/L <mg/L 7/17/05 SIU 0.0752 <0.005 0.0025 0.0016 1.02 1.02 0.6397 7/24/05 POTW 0.0469 <0.005 0.0025 0.0010 1.10 1.1 0.4303 8/7/05 SIU 0.0313 <0.005 0.0025 0.0007 1.31 1.31 0.3420 8/23/05 SIU 0.0538 9/3/05 SIU 0.079 <0.005 0.0025 0.0016 0.78 0.78 0.5139 10/9/05 SIU 0.0676 <0.005 0.0025 0.0014 0.91 0.91 0.5130 10/21/05 SIU 0.0681 11/1/05 SIU 0.0657 <0.005 0.0025 0.0014 0.96 0.96 0.5260 11/16/05 SIU 0.0678 12/11/05 SIU 0.0292 <0.005 0.0025 0.0006 0.71 0.71 0.1729 Column Averages =>0.0585 0.0025 0.0012 0.9700 0.4483 Maximum 0.0790 0.0025 0.0016 1.3100 0.6397 Minimum 0.0292 0.0025 0.0006 0.7100 0.1729 Sample Location: Will Plateit 38 Data Summary Form FLOW OIL & GREASE Phosphorus Sample Date POTW or SIU Sample MGD <mg/L <mg/L <mg/L 7/17/05 SIU 0.0752 21 21 13.1705 7/24/05 POTW 0.0469 20 20 7.8229 8/7/05 SIU 0.0313 19 19 4.9598 8/23/05 SIU 0.0538 9/3/05 SIU 0.079 15 15 9.8829 10/9/05 SIU 0.0676 21 21 11.8395 10/21/05 SIU 0.0681 11/1/05 SIU 0.0657 16 16 8.7670 11/16/05 SIU 0.0678 12/11/05 SIU 0.0292 23 23 5.6011 Column Averages =>0.0585 19.2857 8.8634 Maximum 0.0790 23.0000 13.1705 Minimum 0.0292 15.0000 4.9598 Sample Location: Will Plateit 39 Examples 40 Example 1 •WillPlateit Metal Finishers •1 st 6-month period •Cadmium Receiving POTW name =>Typicalville IU name =>Will Plateit Receiving POTW NPDES # =>NC0012345 IUP # =>006 Effective date for these Limits =>6/30/2011 Pipe # =>001 Expiration date for these Limits =>12/30/15 40 CFR # =>433.17 if not applicable put N/A THE LIMITS ON THIS PAGE ARE, (Check one below): LIMITS for ENTIRE permit period =>Yes INTERIM Limits for period # 1 =>No INTERIM Limits for period # 2 =>No FINAL Limits Page =>No Concentration Limits Mass-Based Limits Monitoring Frequency Sample Required CONVENTIONAL Daily Monthly Units Daily Monthly Units Collection Laboratory PARAMETERS Max Avg.Max Avg by Industry by POTW Method Detection (C or G)Limits 1.Flow 0.098 MGD MGD Monthly Once/6 Months Metered 2.mg/l lbs/day 3.mg/l lbs/day 4.temperature Deg. C Deg. C 5.pH Std. Units Std. Units OTHER PARAMETERS, Please list alphabetically 6.Cadmium 0.07 mg/l lbs/day Monthly Once/6 Months C 0.002 7.Chromium 1.71 mg/l lbs/day Monthly Once/6 Months C 0.005 8.Copper 2.07 mg/l lbs/day Monthly Once/6 Months C 0.002 9.Cyanide 0.01 mg/l lbs/day Monthly Once/6 Months G 0.01 10.Lead 0.43 mg/l lbs/day Monthly Once/6 Months C 0.01 11.Mercury 0.0002 mg/l lbs/day Monthly Once/6 Months C 0.0002 12.Nickel 2.38 mg/l lbs/day Monthly Once/6 Months C 0.01 13.Phosphorous 30 mg/l lbs/day Monthly Once/6 Months C 0.05 14.Silver 0.24 mg/l lbs/day Monthly Once/6 Months C 0.005 15.Zinc 1.48 mg/l lbs/day Monthly Once/6 Months C 0.01 16.TTO 2.13*mg/l lbs/day Once/6 Months G 0.005 17.mg/l lbs/day 18.mg/l lbs/day 19.mg/l lbs/day 20.mg/l lbs/day *See Special Conditions, Part III (See next section, IUP, PART I, Section G.) for Definitions and Limit Page(s) notes: IUP, PART I, Page: 5 IUP, Part I, Section F: Effluent Limits and Monitoring Requirements: The permittee may discharge from this specific pipe number according to these 42 Compliance Judgment Worksheet For SNC With Limits Use separate sheets for each Industry SNC determination for Flow optional, see Section 7-E Use separate sheets for each Pollutant SIU Name: WillPlateit Metal Finishers IUP Number: 0006 Pipe Number: 0001 Parameter: Cadmium Six Month SNC Determination Period: 1/1/2024-6/30/24 See next page for definitions Daily Max. or ____ Ave. Limits from IUP IUP Limit * TRC criteria = TRC Limit Circle 1.4 For TRC for BOD, TSS, oil, fat, grease; Circle 1.2 for all other pollutants TRC compliance judgment not required for pH: Circle which units apply to each individual Limit Daily Maximum Limit: * 1.2 or 1.4 = TRC Daily Limit: mg/l or lbs/day ______ Average Limit: * 1.2 or 1.4 = TRC Avg. Limit: mg/l or lbs/day Column 1: I - Industry self P-POTW A - Average Column 5: Use only if IUP has (monthly, or other?) average limit. Average values of all sampling events collected within the "average" period (for example, for a monthly average limit, use all values collected within a calendar month) and enter this average in column 5. Compare this average to the appropriate average IUP limit or TRC limit. Column 6: Use only if IUP has daily limits in lbs/day. Formula to use is ( mgd * mg/l * 8.34 = lbs/day ). Column 7: Use only if IUP has (monthly?) average limits in lbs/day. Use ( mgd * mg/l * 8.34 = lbs/day ). Column 8: Put "1" for each daily maximum or average value, tally up at bottom as "A." Column 9: Compare daily and average values to IUP limits above,put "0" if at or below limit, "1" if above, tally at bottom as "B." Column 10: Compare daily and average values to TRC limits above,put "0" if below limit, "1" if at or above, tally at bottom as "C." Col. 1: From IDMRs From IDMRs From IDMRs Col. 5: Col 6: Col 7: Col 8: Col 9: Col 10: Sample Type Sample Date Daily Flow, mgd Daily Conc. mg/l Avg Conc. mg/l Daily Load lbs/day Avg. Load lbs/day Count Regular Violation ? TRC Violation ? I 1/7/12 .0691 .059 P 2/1/12 .0543 .060 I 2/4/12 .0783 .062 I 3/6/12 .0796 .096 I 3/22/12 .0748 .102 I 4/2/12 .0667 .083 I 4/17/12 .0612 .082 I 5/1/12 .0342 .078 I 5/16/12 .0589 .079 I 6/3/12 .0547 .064 I 6/18/12 .0693 .080 I 6/30/12 .0712 .076 List these Totals on next page => A = B = C= 43 Count - The number of daily or the number of average sample values used for checking compliance. (Daily values for this example) Compliance Judgment Worksheet For SNC With Limits Use separate sheets for each Industry SNC determination for Flow optional, see Section 7-E Use separate sheets for each Pollutant SIU Name: WillPlateit Metal Finishers IUP Number: 0006 Pipe Number: 0001 Parameter: Cadmium Six Month SNC Determination Period: 1/1/2012-6/30/12 See next page for definitions Daily Max. or ____ Ave. Limits from IUP IUP Limit * TRC criteria = TRC Limit Circle 1.4 For TRC for BOD, TSS, oil, fat, grease; Circle 1.2 for all other pollutants TRC compliance judgment not required for pH: Circle which units apply to each individual Limit Daily Maximum Limit: * 1.2 or 1.4 = TRC Daily Limit: mg/l or lbs/day ______ Average Limit: * 1.2 or 1.4 = TRC Avg. Limit: mg/l or lbs/day Column 1: I - Industry self P-POTW A - Average Column 5: Use only if IUP has (monthly, or other?) average limit. Average values of all sampling events collected within the "average" period (for example, for a monthly average limit, use all values collected within a calendar month) and enter this average in column 5. Compare this average to the appropriate average IUP limit or TRC limit. Column 6: Use only if IUP has daily limits in lbs/day. Formula to use is ( mgd * mg/l * 8.34 = lbs/day ). Column 7: Use only if IUP has (monthly?) average limits in lbs/day. Use ( mgd * mg/l * 8.34 = lbs/day ). Column 8: Put "1" for each daily maximum or average value, tally up at bottom as "A." Column 9: Compare daily and average values to IUP limits above,put "0" if at or below limit, "1" if above, tally at bottom as "B." Column 10: Compare daily and average values to TRC limits above,put "0" if below limit, "1" if at or above, tally at bottom as "C." Col. 1: From IDMRs From IDMRs From IDMRs Col. 5: Col 6: Col 7: Col 8: Col 9: Col 10: Sample Type Sample Date Daily Flow, mgd Daily Conc. mg/l Avg Conc. mg/l Daily Load lbs/day Avg. Load lbs/day Count Regular Violation ? TRC Violation ? I 1/7/12 .0691 .059 1 P 2/1/12 .0543 .060 1 I 2/4/12 .0783 .062 1 I 3/6/12 .0796 .096 1 I 3/22/12 .0748 .102 1 I 4/2/12 .0667 .083 1 I 4/17/12 .0612 .082 1 I 5/1/12 .0342 .078 1 I 5/16/12 .0589 .079 1 I 6/3/12 .0547 .064 1 I 6/18/12 .0693 .080 1 I 6/30/12 .0712 .076 1 List these Totals on next page => A = 12 B = C= .07 .084 44 Compliance Judgment Worksheet For SNC With Limits Use separate sheets for each Industry SNC determination for Flow optional, see Section 7-E Use separate sheets for each Pollutant SIU Name: WillPlateit Metal Finishers IUP Number: 0006 Pipe Number: 0001 Parameter: Cadmium Six Month SNC Determination Period: 1/1/2012-6/30/12 See next page for definitions Daily Max. or ____ Ave. Limits from IUP IUP Limit * TRC criteria = TRC Limit Circle 1.4 For TRC for BOD, TSS, oil, fat, grease; Circle 1.2 for all other pollutants TRC compliance judgment not required for pH: Circle which units apply to each individual Limit Daily Maximum Limit: * 1.2 or 1.4 = TRC Daily Limit: mg/l or lbs/day ______ Average Limit: * 1.2 or 1.4 = TRC Avg. Limit: mg/l or lbs/day Column 1: I - Industry self P-POTW A - Average Column 5: Use only if IUP has (monthly, or other?) average limit. Average values of all sampling events collected within the "average" period (for example, for a monthly average limit, use all values collected within a calendar month) and enter this average in column 5. Compare this average to the appropriate average IUP limit or TRC limit. Column 6: Use only if IUP has daily limits in lbs/day. Formula to use is ( mgd * mg/l * 8.34 = lbs/day ). Column 7: Use only if IUP has (monthly?) average limits in lbs/day. Use ( mgd * mg/l * 8.34 = lbs/day ). Column 8: Put "1" for each daily maximum or average value, tally up at bottom as "A." Column 9: Compare daily and average values to IUP limits above,put "0" if at or below limit, "1" if above, tally at bottom as "B." Column 10: Compare daily and average values to TRC limits above,put "0" if below limit, "1" if at or above, tally at bottom as "C." Col. 1: From IDMRs From IDMRs From IDMRs Col. 5: Col 6: Col 7: Col 8: Col 9: Col 10: Sample Type Sample Date Daily Flow, mgd Daily Conc. mg/l Avg Conc. mg/l Daily Load lbs/day Avg. Load lbs/day Count Regular Violation ? TRC Violation ? I 1/7/23 .0691 .059 1 0 P 2/1/12 .0543 .060 1 0 I 2/4/12 .0783 .062 1 0 I 3/6/12 .0796 .096 1 1 I 3/22/12 .0748 .102 1 1 I 4/2/12 .0667 .083 1 1 I 4/17/12 .0612 .082 1 1 I 5/1/12 .0342 .078 1 1 I 5/16/12 .0589 .079 1 1 I 6/3/12 .0547 .064 1 0 I 6/18/12 .0693 .080 1 1 I 6/30/12 .0712 .076 1 1 List these Totals on next page => A = 12 B = 8 C= .07 .084 45 Compliance Judgment Worksheet For SNC With Limits Use separate sheets for each Industry SNC determination for Flow optional, see Section 7-E Use separate sheets for each Pollutant SIU Name: WillPlateit Metal Finishers IUP Number: 0006 Pipe Number: 0001 Parameter: Cadmium Six Month SNC Determination Period: 1/1/2012-6/30/12 See next page for definitions Daily Max. or ____ Ave. Limits from IUP IUP Limit * TRC criteria = TRC Limit Circle 1.4 For TRC for BOD, TSS, oil, fat, grease; Circle 1.2 for all other pollutants TRC compliance judgment not required for pH: Circle which units apply to each individual Limit Daily Maximum Limit: * 1.2 or 1.4 = TRC Daily Limit: mg/l or lbs/day ______ Average Limit: * 1.2 or 1.4 = TRC Avg. Limit: mg/l or lbs/day Column 1: I - Industry self P-POTW A - Average Column 5: Use only if IUP has (monthly, or other?) average limit. Average values of all sampling events collected within the "average" period (for example, for a monthly average limit, use all values collected within a calendar month) and enter this average in column 5. Compare this average to the appropriate average IUP limit or TRC limit. Column 6: Use only if IUP has daily limits in lbs/day. Formula to use is ( mgd * mg/l * 8.34 = lbs/day ). Column 7: Use only if IUP has (monthly?) average limits in lbs/day. Use ( mgd * mg/l * 8.34 = lbs/day ). Column 8: Put "1" for each daily maximum or average value, tally up at bottom as "A." Column 9: Compare daily and average values to IUP limits above,put "0" if at or below limit, "1" if above, tally at bottom as "B." Column 10: Compare daily and average values to TRC limits above,put "0" if below limit, "1" if at or above, tally at bottom as "C." Col. 1: From IDMRs From IDMRs From IDMRs Col. 5: Col 6: Col 7: Col 8: Col 9: Col 10: Sample Type Sample Date Daily Flow, mgd Daily Conc. mg/l Avg Conc. mg/l Daily Load lbs/day Avg. Load lbs/day Count Regular Violation ? TRC Violation ? I 1/7/23 .0691 .059 1 0 0 P 2/1/12 .0543 .060 1 0 0 I 2/4/12 .0783 .062 1 0 0 I 3/6/12 .0796 .096 1 1 1 I 3/22/12 .0748 .102 1 1 1 I 4/2/12 .0667 .083 1 1 0 I 4/17/12 .0612 .082 1 1 0 I 5/1/12 .0342 .078 1 1 0 I 5/16/12 .0589 .079 1 1 0 I 6/3/012 .0547 .064 1 0 0 I 6/18/12 .0693 .080 1 1 0 I 6/30/12 .0712 .076 1 1 0 List these Totals on next page => A = 12 B = 8 C= 2 .07 .084 46 Compliance Judgment Worksheet For SNC With Limits Use separate sheets for each Industry SNC determination for Flow optional, see Section 7-E Use separate sheets for each Pollutant SIU Name: WillPlateit Metal Finishers IUP Number: 0006 Pipe Number: 0001 Parameter: Cadmium Six Month SNC Determination Period: 1/1/2012-6/30/12 SIGNIFICANT NON-COMPLIANCE (SNC) LIMITS DETERMINATION Calculate % and Circle Answers 1) Calculate the % of Regular violations: B/A = 2) Is B/A greater than or equal to 0.66 (or 66 %) ? Chronic violator? Yes / No 3) Calculate the % of TRC Violations: C/A = 4) Is C/A greater than or equal to 0.33 (or 33 %) ? TRC Violator? Yes / No 5) Did any violation, alone or in combination with other discharges, cause pass-through or interference at the POTW, or endanger the health of POTW workers or the public? Yes / No 6) Did any violation cause 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 discharge? Yes / No 7) If the answer to any of these questions is yes, the SIU is in Significant Non-Compliance (SNC) for this parameter. They must be listed on the Significant Non-Compliance Report (SNCR) form in the Pretreatment Annual Report (PAR), described in the PAR narrative (including parameter, period, and POTW actions), and the POTW must take adequate enforcement as outlined in its Enforcement Response Plan (ERP). Is the SIU in SNC for this six month period? CIRCLE ONE: YES NO Was the SIU in SNC for THE SAME PARAMETER in the previous six month compliance period? CIRCLE ONE: YES NO If YES to EITHER question, DESCRIBE IN NARRATIVE. Please note if SIU was in SNC for the previous six month compliance period and is also in SNC for this six month compliance period, escalated enforcement actions must be taken as soon as possible, preferably before the end of the second consecutive period. Failure to take the action within 2 months after the end of the second consecutive period will subject the POTW to enforcement by the Division. The options are: Consent Order with Enforceable schedule; Administrative Order with Enforceable schedule;or Permit modification. See Chapter 9 - Pretreatment Annual Reports, Chapter 8 - Enforcement, and the POTW's Enforcement Response Plan (ERP). Definitions: Count, The number of daily sample data values or the number of average of sampling events used for checking compliance with average limits. TRC Technical Review Criteria, Multiply the actual IUP limits by the proper TRC Criteria value to get a TRC Limit: TRC Criteria = 1.4 for BOD, TSS, oil, fat, grease TRC Criteria = 1.2 for all other pollutants Not required to perform TRC compliance judgment for pH. SNCR Significant Non-Compliance Report SNC Significant Non-Compliance 66.7%8/12 2/12 16.7% Per ORC 47 Example 2 •WillPlateit Metal Finishers •2 nd 6 -month period •Cadmium Compliance Judgment Worksheet For SNC With Limits Use separate sheets for each Industry SNC determination for Flow optional, see Section 7-E Use separate sheets for each Pollutant SIU Name: WillPlateit Metal Finishers IUP Number: 0006 Pipe Number: 0001 Parameter: Cadmium Six Month SNC Determination Period:7/1/2012-12/31/12 See next page for definitions Daily Max. or ____ Ave. Limits from IUP IUP Limit * TRC criteria = TRC Limit Circle 1.4 For TRC for BOD, TSS, oil, fat, grease; Circle 1.2 for all other pollutants TRC compliance judgment not required for pH: Circle which units apply to each individual Limit Daily Maximum Limit: * 1.2 or 1.4 = TRC Daily Limit: mg/l or lbs/day ______ Average Limit: * 1.2 or 1.4 = TRC Avg. Limit: mg/l or lbs/day Column 1: I - Industry self P-POTW A - Average Column 5: Use only if IUP has (monthly, or other?) average limit. Average values of all sampling events collected within the "average" period (for example, for a monthly average limit, use all values collected within a calendar month) and enter this average in column 5. Compare this average to the appropriate average IUP limit or TRC limit. Column 6: Use only if IUP has daily limits in lbs/day. Formula to use is ( mgd * mg/l * 8.34 = lbs/day ). Column 7: Use only if IUP has (monthly?) average limits in lbs/day. Use ( mgd * mg/l * 8.34 = lbs/day ). Column 8: Put "1" for each daily maximum or average value, tally up at bottom as "A." Column 9: Compare daily and average values to IUP limits above,put "0" if at or below limit, "1" if above, tally at bottom as "B." Column 10: Compare daily and average values to TRC limits above,put "0" if below limit, "1" if at or above, tally at bottom as "C." Col. 1: From IDMRs From IDMRs From IDMRs Col. 5: Col 6: Col 7: Col 8: Col 9: Col 10: Sample Type Sample Date Daily Flow, mgd Daily Conc. mg/l Avg Conc. mg/l Daily Load lbs/day Avg. Load lbs/day Count Regular Violation ? TRC Violation ? I 7/17/12 .0752 .042 P 7/24/12 .0469 .086 I 8/7/12 .0313 .087 I 8/23/12 .0538 .077 I 9/3/12 .0790 .067 I 10/9/12 .0676 .089 I 10/21/12 .0681 .076 I 11/1/12 .0657 .091 I 11/16/12 .0678 .069 I 12/17/12 .0292 .057 List these Totals on next page => A = B = C= 49 Compliance Judgment Worksheet For SNC With Limits Use separate sheets for each Industry SNC determination for Flow optional, see Section 7-E Use separate sheets for each Pollutant SIU Name: WillPlateit Metal Finishers IUP Number: 0006 Pipe Number: 0001 Parameter: Cadmium Six Month SNC Determination Period: 7/1/2012-12/31/12 See next page for definitions Daily Max. or ____ Ave. Limits from IUP IUP Limit * TRC criteria = TRC Limit Circle 1.4 For TRC for BOD, TSS, oil, fat, grease; Circle 1.2 for all other pollutants TRC compliance judgment not required for pH: Circle which units apply to each individual Limit Daily Maximum Limit: * 1.2 or 1.4 = TRC Daily Limit: mg/l or lbs/day ______ Average Limit: * 1.2 or 1.4 = TRC Avg. Limit: mg/l or lbs/day Column 1: I - Industry self P-POTW A - Average Column 5: Use only if IUP has (monthly, or other?) average limit. Average values of all sampling events collected within the "average" period (for example, for a monthly average limit, use all values collected within a calendar month) and enter this average in column 5. Compare this average to the appropriate average IUP limit or TRC limit. Column 6: Use only if IUP has daily limits in lbs/day. Formula to use is ( mgd * mg/l * 8.34 = lbs/day ). Column 7: Use only if IUP has (monthly?) average limits in lbs/day. Use ( mgd * mg/l * 8.34 = lbs/day ). Column 8: Put "1" for each daily maximum or average value, tally up at bottom as "A." Column 9: Compare daily and average values to IUP limits above,put "0" if at or below limit, "1" if above, tally at bottom as "B." Column 10: Compare daily and average values to TRC limits above,put "0" if below limit, "1" if at or above, tally at bottom as "C." Col. 1: From IDMRs From IDMRs From IDMRs Col. 5: Col 6: Col 7: Col 8: Col 9: Col 10: Sample Type Sample Date Daily Flow, mgd Daily Conc. mg/l Avg Conc. mg/l Daily Load lbs/day Avg. Load lbs/day Count Regular Violation ? TRC Violation ? I 7/17/12 .0752 .042 1 P 7/24/12 .0469 .086 1 I 8/7/12 .0313 .087 1 I 8/23/12 .0538 .077 1 I 9/3/12 .0790 .067 1 I 10/9/12 .0676 .089 1 I 10/21/12 .0681 .076 1 I 11/1/12 .0657 .091 1 I 11/16/12 .0678 .069 1 I 12/17/12 .0292 .057 1 List these Totals on next page => A = 10 B = C= .07 .084 50 Compliance Judgement Worksheet For SNC With Limits Use separate sheets for each Industry SNC determination for Flow optional, see Section 7-E Use separate sheets for each Pollutant SIU Name: WillPlateit Metal Finishers IUP Number: 0006 Pipe Number: 0001 Parameter: Cadmium Six Month SNC Determination Period: 7/1/2012-12/31/12 See next page for definitions Daily Max. or ____ Ave. Limits from IUP IUP Limit * TRC criteria = TRC Limit Circle 1.4 For TRC for BOD, TSS, oil, fat, grease; Ci rcle 1.2 for all other pollutants TRC compliance judgment not required for pH: Circle which units apply to each individual Limit Daily Maximum Limit: * 1.2 or 1.4 = TRC Daily Limit: mg/l or lbs/day ______ Average Limit: * 1.2 or 1.4 = TRC Avg. Limit: mg/l or lbs/day Column 1: I - Industry self P-POTW A - Average Column 5: Use only if IUP has (monthly, or other?) average limit. Average values of all sampling events collected within the "average" period (for example, for a monthly average limit, use all values collected within a calendar month) and enter this average in column 5. Compare this average to the appropriate average IUP limit or TRC limit. Column 6: Use only if IUP has daily limits in lbs/day. Formula to use is ( mgd * mg/l * 8.34 = lbs/day ). Column 7: Use only if IUP has (monthly?) average limits in lbs/day. Use ( mgd * mg/l * 8.34 = lbs/day ). Column 8: Put "1" for each daily maximum or average value, tally up at bottom as "A." Column 9: Compare daily and average values to IUP limits above,put "0" if at or below limit, "1" if above, tally at bottom as "B." Column 10: Compare daily and average values to TRC limits above,put "0" if below limit, "1" if at or above, tally at bottom as "C." Col. 1: From IDMRs From IDMRs From IDMRs Col. 5: Col 6: Col 7: Col 8: Col 9: Col 10: Sample Type Sample Date Daily Flow, mgd Daily Conc. mg/l Avg Conc. mg/l Daily Load lbs/day Avg. Load lbs/day Count Regular Violation ? TRC Violation ? I 7/17/12 .0752 .042 1 0 P 7/24/12 .0469 .086 1 1 I 8/7/12 .0313 .087 1 1 I 8/23/12 .0538 .077 1 1 I 9/3/12 .0790 .067 1 0 I 10/9/12 .0676 .089 1 1 I 10/21/12 .0681 .076 1 1 I 11/1/12 .0657 .091 1 1 I 11/16/12 .0678 .069 1 0 I 12/17/12 .0292 .057 1 0 List these Totals on next page => A = 10 B = 6 C= .07 .084 51 Compliance Judgment Worksheet For SNC With Limits Use separate sheets for each Industry SNC determination for Flow optional, see Section 7-E Use separate sheets for each Pollutant SIU Name: WillPlateit Metal Finishers IUP Number: 0006 Pipe Number: 0001 Parameter: Cadmium Six Month SNC Determination Period: 7/1/2012-12/31/12 See next page for definitions Daily Max. or ____ Ave. Limits from IUP IUP Limit * TRC criteria = TRC Limit Circle 1.4 For TRC for BOD, TSS, oil, fat, grease; Circle 1.2 for all other pollutants TRC compliance judgment not required for pH: Circle which units apply to each individual Limit Daily Maximum Limit: * 1.2 or 1.4 = TRC Daily Limit: mg/l or lbs/day ______ Average Limit: * 1.2 or 1.4 = TRC Avg. Limit: mg/l or lbs/day Column 1: I - Industry self P-POTW A - Average Column 5: Use only if IUP has (monthly, or other?) average limit. Average values of all sampling events collected within the "average" period (for example, for a monthly average limit, use all values collected within a calendar month) and enter this average in column 5. Compare this average to the appropriate average IUP limit or TRC limit. Column 6: Use only if IUP has daily limits in lbs/day. Formula to use is ( mgd * mg/l * 8.34 = lbs/day ). Column 7: Use only if IUP has (monthly?) average limits in lbs/day. Use ( mgd * mg/l * 8.34 = lbs/day ). Column 8: Put "1" for each daily maximum or average value, tally up at bottom as "A." Column 9: Compare daily and average values to IUP limits above,put "0" if at or below limit, "1" if above, tally at bottom as "B." Column 10: Compare daily and average values to TRC limits above,put "0" if below limit, "1" if at or above, tally at bottom as "C." Col. 1: From IDMRs From IDMRs From IDMRs Col. 5: Col 6: Col 7: Col 8: Col 9: Col 10: Sample Type Sample Date Daily Flow, mgd Daily Conc. mg/l Avg Conc. mg/l Daily Load lbs/day Avg. Load lbs/day Count Regular Violation ? TRC Violation ? I 7/17/12 .0752 .042 1 0 0 P 7/24/12 .0469 .086 1 1 1 I 8/7/12 .0313 .087 1 1 1 I 8/23/12 .0538 .077 1 1 0 I 9/3/12 .0790 .067 1 0 0 I 10/9/12 .0676 .089 1 1 1 I 10/21/12 .0681 .076 1 1 0 I 11/1/12 .0657 .091 1 1 1 I 11/16/12 .0678 .069 1 0 0 I 12/17/12 .0292 .057 1 0 0 List these Totals on next page => A = 10 B = 6 C= 4 .07 .084 52 Compliance Judgement Worksheet For SNC With Limits Use separate sheets for each Industry SNC determination for Flow optional, see Section 7-E Use separate sheets for each Pollutant SIU Name: WillPlateit Metal Finishers IUP Number: 0006 Pipe Number: 0001 Parameter: Cadmium Six Month SNC Determination Period: 7/1/2012-12/31/12 SIGNIFICANT NON-COMPLIANCE (SNC) LIMITS DETERMINATION Calculate % and Circle Answers 1) Calculate the % of Regular violations: B/A = 2) Is B/A greater than or equal to 0.66 (or 66 %) ? Chronic violator? Yes / No 3) Calculate the % of TRC Violations: C/A = 4) Is C/A greater than or equal to 0.33 (or 33 %) ? TRC Violator? Yes / No 5) Did any violation, alone or in combination with other discharges, cause pass-through or interference at the POTW, or endanger the health of POTW workers or the public? Yes / No 6) Did any violation cause 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 discharge? Yes / No 7) If the answer to any of these questions is yes, the SIU is in Significant Non-Compliance (SNC) for this parameter. They must be listed on the Significant Non-Compliance Report (SNCR) form in the Pretreatment Annual Report (PAR), described in the PAR narrative (including parameter, period, and POTW actions), and the POTW must take adequate enforcement as outlined in its Enforcement Response Plan (ERP). Is the SIU in SNC for this six month period? CIRCLE ONE: YES NO Was the SIU in SNC for THE SAME PARAMETER in the previous six month compliance period? CIRCLE ONE: YES NO If YES to EITHER question, DESCRIBE IN NARRATIVE. Please note if SIU was in SNC for the previous six month compliance period and is also in SNC for this six month compliance period, escalated enforcement actions must be taken as soon as possible, preferably before the end of the second consecutive period. Failure to take the action within 2 months after the end of the second consecutive period will subject the POTW to enforcement by the Division. The options are: Consent Order with Enforceable schedule; Administrative Order with Enforceable schedule; Permit modification. See Chapter 9 - Pretreatment Annual Reports, Chapter 8 - Enforcement, and the POTW's Enforcement Response Plan (ERP). Definitions: Count, The number of daily sample data values or the number of average of sampling events used for checking compliance with average limits. TRC Technical Review Criteria, Multiply the actual IUP limits by the proper TRC Criteria value to get a TRC Limit: TRC Criteria = 1.4 for BOD, TSS, oil, fat, grease TRC Criteria = 1.2 for all other pollutants Not required to perform TRC compliance judgment for pH. SNCR Significant Non-Compliance Report SNC Significant Non-Compliance 60.0% 6/10 4/10 40.0% Per ORC Now What? 53 Separate Judgment Please note: Compliance for daily max & monthly (or other) average limits are judged independently and equally weighted. More compliance violations are a potential for more SNC determinations. 54 Setting Pollutant Limits Options Different limit configurations may have an effect on SNC determinations 1.Keep same daily max and monthly average limits a.No change to allocation table b.Must perform SNC calculations treating daily & monthly limits separately •Some POTWs may have to revise compliance judgment software programs c.May cause more SIU violations and SNC 2.Remove monthly avg. Daily max = old monthly avg a.No change to allocation table b.Simplifies compliance judgment c.May cause more SIU violations and SNC Note: Options 2 & 3 may not be available for some categorical SIUs. Contact Pretreatment Staff to discuss. 55 Setting Pollutant Limits Options 3.Remove monthly average limit and keep daily max limit a. Have to use the higher daily max limit in allocation table. •May reduce reserve; may cause over-allocation! b. Simplifies compliance judgment c. Should not create more violations 4. Keep different daily max and monthly average limits a.The allocation table will use monthly averages b.Too conservative limits can cause SNC problems c.Must perform SNC calculations treating daily & monthly limits separately •Some POTWs may have to revise compliance judgment software programs Note: Options 2 & 3 may not be available for some categorical SIUs. Contact Pretreatment Staff to discuss. 56 Data Summary Form as Limits Compliance Judgment Worksheet FLOW ARSENIC CADMIUM CHROMIUM COPPER Sample Date POTW or SIU Sample MGD <mg/L <mg/L <mg/L 7/17/12 SIU 0.0752 0.042 0.042 0.0263 0.32 0.315 0.1976 7/24/12 POTW 0.0469 0.086 0.086 0.0336 0.53 0.532 0.2081 8/7/12 SIU 0.0313 0.087 0.087 0.0227 0.37 0.373 0.0974 8/23/12 SIU 0.0538 0.077 0.077 0.0345 9/3/12 SIU 0.079 0.067 0.067 0.0441 0.82 0.818 0.5389 10/9/12 SIU 0.0676 0.089 0.089 0.0502 0.23 0.231 0.1302 10/21/12 SIU 0.0681 0.076 0.076 0.0432 11/1/12 SIU 0.0657 0.091 0.091 0.0499 0.21 0.206 0.1129 11/16/12 SIU 0.0678 0.069 0.069 0.0390 12/11/12 SIU 0.0292 0.057 0.057 0.0139 0.72 0.721 0.1756 Column Averages =>0.0585 0.0741 0.0357 0.4566 0.2087 Maximum 0.0790 0.0910 0.0502 0.8180 0.5389 Minimum 0.0292 0.0420 0.0139 0.2060 0.0974 Sample Location: Will Plateit Limit = 0.07 mg/l TRC = 0.084 6 Viol = 6/10 =60% 4 TRC = 4/10 = 40% 10 daily samples 57 Industrial Data Summary Form (IDSF) Industrial Data Summary Form (IDSF) •Summarizes All Data Collected for an Industry: 1) SIU and POTW Sampling for Limited Parameters 2) SIU and POTW Sampling for “Monitoring Only” Parameters •Required to Complete a Separate IDSF for Each Pipe for Each SIU •Third party software developers have created solutions for data collection. 59 You May Use Your Own Form with Prior Division Approval of the Form Industrial Data Summary Form (IDSF) •For Each Parameter, Include at Least One of the Following: 1) Maximum Concentration 2) Maximum Loading 3) Average Concentration •Specifying what type of average •If BDL - was ½BDL, or 0 used 4) Average Loading If readily available, the Division prefers both maximum and average values 60 Industrial Data Summary Form (IDSF) •Blank sections indicate that there was no monitoring performed for a particular parameter during a six-month period. •For “monitoring only” parameters - list “N/A” for not applicable in the % violations and % TRC violations rows (do not list “0”) 61 Control Authority,Industry Town Name =>Typicalville Name Chicken Pluckers, Inc. WWTP Name =>Typicalville WWTP IUP #0008 NPDES # =>NC0012345 Pipe #001 1st 6 months, dates =>1/1/2012 to 6/30/2012 2nd 6 months, dates =>7/1/2012 to 12/31/2012 Flow, mgd BOD TSS Ammonia 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months Total # of samples =>121 123 13 32 13 27 1 1 *Maximum (mg/l) =>0.712 mgd 0.806 mgd 725 587 162 114 23.6 14.60 *or Maximum (lb/d) =>4,220 2448 960 703.6 168.28 103.99 *or 6 month using BDL Average (mg/l) =>0.586 mgd 0.613 mgd 445 304 142 47 23.6 14.60 *or Average Loading (lb/d) =>2,175 1554 694 274.00 168.28 103.99 % violations,(chronic SNC is >= 66%) =>0 0 15.4 3.1 0 0 N/A N/A % TRC violations, (SNC is >= 33 %) =>0 0 7.7 0 0 0 N/A N/A % violations,(chronic SNC is >= 66%) =>N/A N/A 100 33.3 0 0 N/A N/A % TRC violations, (SNC is >= 33 %) =>N/A N/A 66.7 0 0 0 N/A N/A Oil & Grease Zinc pH 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months Total # of samples =>7 7 1 1 13 27 *Maximum (mg/l) =>25.5 62.1 0.11 0.08 5.0/9.75 6.5/9.5 *or Maximum (lb/d) =>170.14 447.48 0.6752 0.5698 *or 6 month using BDL Average (mg/l) =>11.75 27 0.11 0.08 *or Average Loading (lb/d) =>79.8 189.69 0.6752 0.5698 % violations, (chronic SNC is >= 66%) =>0 0 N/A N/A 15.4 0 % TRC violations, (SNC is >= 33 %) =>0 0 N/A N/A N/A N/A % violations,(chronic SNC is >= 66%) =>N/A N/A N/A N/A N/A N/A % TRC violations, (SNC is >= 33 %) =>N/A N/A N/A N/A N/A N/A BDL => Below Detection Limit mg/l => milligrams per liter * POTW must enter at least one of these IUP => Industrial User Permit lb/d => pounds per day four rows, Please indicate how averages were calculated SNC => Significant Non-Compliance mgd => million gallons per day Avg period could be month, Qtr, or 6-month & if BDL , 1/2BDL, or zero values used.TRC => Technical Review Criteria WWTP => wastewater treatment plant Pretreatment Annual Report (PAR) Industrial Data Summary Form (IDSF) Use separate forms for each industry/pipe Pretreatment Annual Report (PAR)N/A because no IUP Limit for these Parameters IDSF for SIUs with both daily and average limits 62 Control Authority,Industry Town Name =>Typicalville Name Slugem Hosiery Mill, Inc. WWTP Name =>Typicalville WWTP IUP #0007 NPDES # =>NC0012345 Pipe #001 1st 6 months, dates =>1/1/2012 to 6/30/12 2nd 6 months, dates =>7/1/2012 to 12/31/12 Flow, mgd BOD TSS Ammonia 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months Total # of samples =>12 10 12 10 7 7 1 *Maximum (mg/l) =>0.248 mgd 0.358 mgd 177 325 367 330 5.4 *or Maximum (lb/d) =>342.62 737.26 752.96 864.19 not 15.23 *or 6 month using BDL Average (mg/l) =>0.197 mgd 0.313 mgd 157 226 0.252 218 required 5.4 *or Average Loading (lb/d) =>257.34 571.23 431.18 549.46 15.23 % violations,(chronic SNC is >= 66%) =>0 0 0 0 0 0 N/A % TRC violations, (SNC is >= 33 %) =>0 0 0 0 0 0 N/A Chromium Copper Mercury Zinc 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months Total # of samples =>8 8 8 7 1 7 7 *Maximum (mg/l) =>0.48 0.460 0.49 0.49 0.0002 0.187 0.501 *or Maximum (lb/d) =>0.863 1.3730 0.94 1.314 not 0.0006 0.359 1.32 *or 6 month using BDL Average (mg/l) =>0.407 0.390 0.393 0.383 required 0.0002 0.162 0.359 *or Average Loading (lb/d) =>0.693 1.0190 0.667 0.999 0.0006 0.266 0.935 % violations, (chronic SNC is >= 66%) =>12.5 0 12.5 0 N/A 0 0 % TRC violations, (SNC is >= 33 %) =>0 0 0 0 N/A 0 0 Oil & Grease MBAS Phosphorous 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months Total # of samples =>7 7 1 7 7 *Maximum (mg/l) =>75.9 79 0.12 10.8 15.7 *or Maximum (lb/d) =>124.33 205 not 0.358 20.767 35.72 *or 6 month using BDL Average (mg/l) =>45.5 62.78 required 0.12 9.11 12.48 *or Average Loading (lb/d) =>66.9 161.6 0.358 15.181 32.24 % violations, (chronic SNC is >= 66%) =>0 0 N/A 0 % TRC violations, (SNC is >= 33 %) =>0 0 N/A 0 BDL => Below Detection Limit mg/l => milligrams per liter * POTW must enter at least one of these IUP => Industrial User Permit lb/d => pounds per day four rows, Please indicate how averages were calculated SNC => Significant Non-Compliance mgd => million gallons per day Avg period could be month, Qtr, or 6-month & if BDL , 1/2BDL, or zero values used.TRC => Technical Review Criteria WWTP => wastewater treatment plant Pretreatment Annual Report (PAR) Industrial Data Summary Form (IDSF) Use separate forms for each industry/pipe Enter BDL values as < (value) Pretreatment Annual Report (PAR) Why was this data not required? Discuss in narrative. 63 Control Authority,Industry Town Name =>Typicalville Name Will Plateit Metal Finishing, Inc. WWTP Name =>Typicalville WWTP IUP #0006 NPDES # =>NC0012345 Pipe #001 1st 6 months, dates =>1/1/2012 to 6/30/12 2nd 6 months, dates =>7/1/2012 to 12/31/12 Flow, mgd Cadmium Chromium Copper 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months Total # of samples =>12 10 12 10 7 7 7 7 *Maximum (mg/l) =>0.0796 mgd 0.079 mgd 0.102 0.091 0.012 0.023 1.43 1.830 *or Maximum (lb/d) =>0.0637 0.050 0.0063 0.0095 0.7836 0.7146 *or 6 month using BDL Average (mg/l) =>0.0644 mgd 0.0585 mgd 0.077 0.074 0.008 0.010 1.089 1.245 *or Average Loading (lb/d) =>0.042 0.036 0.0037 0.004 0.5238 0.506 % violations,(chronic SNC is >= 66%) =>0 0 66.7 60 0 0 0 0 % TRC violations, (SNC is >= 33 %) =>0 0 16.7 40 0 0 0 0 Cyanide Lead Mercury Nickel 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months Total # of samples =>7 7 7 7 7 7 10 *Maximum (mg/l) =>0.005 0.005 0.027 0.013 0.0002 2.52 3.03 *or Maximum (lb/d) =>0.0033 0.0033 0.0171 0.0067 Not 0.00013 1.4034 1.7083 *or 6 month using BDL Average (mg/l) =>0.005 0.005 0.021 0.011 Required 0.0002 1.735 2.15 *or Average Loading (lb/d) =>0.0024 0.0021 0.0104 0.0043 0.00013 0.8713 1.0490 % violations, (chronic SNC is >= 66%) =>0 0 0 0 0 14.3 30 % TRC violations, (SNC is >= 33 %) =>0 0 0 0 0 0 20 Silver Zinc Phosphorous TTO 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months Total # of samples =>7 7 7 7 7 7 *Maximum (mg/l) =>0.173 0.171 0.407 0.487 3.84 3.05 *or Maximum (lb/d) =>0.114 0.114 0.2682 0.2198 2.321 1.2677 *or 6 month using BDL Average (mg/l) =>0.125 0.124 0.369 0.34 2.608 2.622 *or Average Loading (lb/d) =>0.064 0.0549 0.1802 0.1339 1.2099 1.0338 % violations, (chronic SNC is >= 66%) =>0 0 0 0 0 0 % TRC violations, (SNC is >= 33 %) =>0 0 0 0 0 0 BDL => Below Detection Limit mg/l => milligrams per liter * POTW must enter at least one of these IUP => Industrial User Permit lb/d => pounds per day four rows, Please indicate how averages were calculated SNC => Significant Non-Compliance mgd => million gallons per day Avg period could be month, Qtr, or 6-month & if BDL , 1/2BDL, or zero values used.TRC => Technical Review Criteria WWTP => wastewater treatment plant *Certifies for TTO as Not Being Present Pretreatment Annual Report (PAR) Industrial Data Summary Form (IDSF) Use separate forms for each industry/pipe Enter BDL values as < (value) 64 Significant Non-Compliance Report (SNCR) 65 Significant Non -Compliance Report (SNCR) •List all IUs in SNC with any IUP requirement for the PAR Year 1) Limits Violations 2) Pass-Through and Interference 3) SNC for Reporting and/or IUP Conditions •POTW must still take that appropriate enforcement or other action for SIUs that will be in SNC for a second consecutive six -month period •Remember, repeat SNCs are a serious matter . 66 PAR covers this calendar year =>2012 Control Authority=Program=Town Name =>Town of Typicalville WWTP = Wastewater Treatment Plant, use separate form for each WWTP.WWTP Name =>Typicalville WWTP SIU = Significant Industrial User NPDES # =>NC0012345 SNC = Significant Non-Compliance A SNCR Form must be submitted with every PAR, please write "None " if you had No SIUs in SNC during calendar year IUP Pipe Industry Name Parameter ##or "Reporting"Jan. - June July - Dec. 0006 001 Will Plateit Metal Finishing, Inc.Cadmium Yes Yes 0008 001 Chicken Pluckers, Inc.BOD Yes No 0008 001 Chicken Pluckers, Inc.Reporting Yes No Attach a copy of the Division's "SIUs in SNC Historical Report" for your POTW's SIUs behind this page . Is the database correct ? Notify the Division of any errors ! Database indicates SNC history for previous years. EVERY SNC MUST be explained in the Narrative, How was, is, or will it be resolved? REPEAT SNCs are serious matters that MUST be explained in the Narrative. SNC ? ( Yes / No ) for each 6-month period. Pretreatment Annual Report (PAR) Significant Non-Compliance Report (SNCR) 67 Note, the Division did not provide an SNC Report for the 2023 PAR Pretreatment Performance Summary (PPS) ▪Form adapted to gather information for the EPA database ▪Counts # of: •SIUs and CIUs •NOVs and similar actions •SIUs in SNC •Public Notices •Enforcement Cases •Penalties Assessed and Collected •Compliance Schedules 69 Pretreatment Performance Summary (PPS)- Explanations •Line # 5. Number of SIUs permitted and/or discharging during the PAR year. Discuss new or dropped SIUs in narrative. •Line # 12. An SIU is in SNC if they fail to meet a compliance schedule milestone within 90 days of the scheduled date for starting construction, completing construction or attaining final compliance; if progress reports required by the compliance schedule are over 45 days late; or there are violations of any interim limits meeting the chronic or TRC definition of SNC. •Line # 15. This is the total number of industries on a compliance schedule as part of an enforcement action during the reporting period. If the compliance schedule was entered into in July 2023, it would be counted on the PPS form in 2023 and 2024 and subsequent PARs years until the schedule is completed or expires. These schedules are issued outside of, or separate from, the IUP. If an industry is on a compliance schedule that is part of an IUP, this is not included in the PAR. This type of compliance schedule is not considered an enforcement action that includes stipulated penalties, and it should therefore not b e included. •Lines # 16,17,18,19, 20. are based on number of events during PAR year, and do not include events occurring after PAR year. •Line # 19. Total amount of Civil Penalties collected: This is the actual amount in fines that was collected from the industri es during this twelve-month period. This can include COLLECTION of penalties assessed during prior reporting periods. •Line # 20. Number of SIUs from which penalties collected. This is the total number of industries that actually paid penalties during the year. 70 Line # 5. Number of SIUs actually permitted and/or discharging during PAR year. Discuss new or dropped SIUs in narrative. Chapter 9, PAR Guidance Pretreatment Performance Summary (PPS) 1.Pretreatment Town Name: 2."Primary" NPDES Number NC00 or Non_Discharge Permit # if applicable => 3.PAR begin Date, please enter 01/01/yy 3. =>1/1/2012 4.PAR end Date, please enter 12/31/yy 4. =>12/31/2012 5.Total number of SIUs, includes CIUs 5. =>3 6.Number of CIUs 6. => 7.Number of SIUs with no IUP, or with an expired IUP 7. => 8.Number of SIUs not inspected by POTW 8. => 9.Number of SIUs not sampled by POTW 9. => 10.Number of SIUs in SNC due to IUP Limit violations 10. => 11.Number of SIUs in SNC due to Reporting violations 11. => 12.Number of SIUs in SNC due to violation of a compliance schedule, CO, AO or similar 12. => 13.Number of CIUs in SNC 13. => 14.Number of SIUs included in public notice 14. => 15 Total number of SIUs on a compliance schedule, CO, AO or similar 15. => 16.Number of NOVs, NNCs or similar assesed to SIUs 16. => 17.Number of Civil Penalties assessed to SIUs 17. => 18.Number of Criminal Penalties assessed to SIUs 18. => 19.Total Amount of Civil Penalties Collected 19. => $ 20.Number of IUs from which penalties collected 20. => Foot Notes: 12345 Typicalville 71 Will Plateit Chapter 9, PAR Guidance Pretreatment Performance Summary (PPS) 1.Pretreatment Town Name: 2."Primary" NPDES Number NC00 or Non_Discharge Permit # if applicable => 3.PAR begin Date, please enter 01/01/yy 3. =>1/1/2012 4.PAR end Date, please enter 12/31/yy 4. =>12/31/2012 5.Total number of SIUs, includes CIUs 5. =>3 6.Number of CIUs 6. =>1 7.Number of SIUs with no IUP, or with an expired IUP 7. =>0 8.Number of SIUs not inspected by POTW 8. =>0 9.Number of SIUs not sampled by POTW 9. =>0 10.Number of SIUs in SNC due to IUP Limit violations 10. =>2 11.Number of SIUs in SNC due to Reporting violations 11. =>1 12.Number of SIUs in SNC due to violation of a compliance schedule, CO, AO or similar 12. =>0 13.Number of CIUs in SNC 13. =>1 14.Number of SIUs included in public notice 14. => 15 Total number of SIUs on a compliance schedule, CO, AO or similar 15. => 16.Number of NOVs, NNCs or similar assesed to SIUs 16. => 17.Number of Civil Penalties assessed to SIUs 17. => 18.Number of Criminal Penalties assessed to SIUs 18. => 19.Total Amount of Civil Penalties Collected 19. => $ 20.Number of IUs from which penalties collected 20. => Foot Notes: 12345 Typicalville Will Plateit 72 Will Plateit Chapter 9, PAR Guidance Pretreatment Performance Summary (PPS) 1.Pretreatment Town Name: 2."Primary" NPDES Number NC00 or Non_Discharge Permit # if applicable => 3.PAR begin Date, please enter 01/01/yy 3. =>1/1/2012 4.PAR end Date, please enter 12/31/yy 4. =>12/31/2012 5.Total number of SIUs, includes CIUs 5. =>3 6.Number of CIUs 6. =>1 7.Number of SIUs with no IUP, or with an expired IUP 7. =>0 8.Number of SIUs not inspected by POTW 8. =>0 9.Number of SIUs not sampled by POTW 9. =>0 10.Number of SIUs in SNC due to IUP Limit violations 10. =>2 11.Number of SIUs in SNC due to Reporting violations 11. =>1 12.Number of SIUs in SNC due to violation of a compliance schedule, CO, AO or similar 12. =>0 13.Number of CIUs in SNC 13. =>1 14.Number of SIUs included in public notice 14. =>2 15 Total number of SIUs on a compliance schedule, CO, AO or similar 15. => 16.Number of NOVs, NNCs or similar assesed to SIUs 16. => 17.Number of Civil Penalties assessed to SIUs 17. => 18.Number of Criminal Penalties assessed to SIUs 18. => 19.Total Amount of Civil Penalties Collected 19. => $ 20.Number of IUs from which penalties collected 20. => Foot Notes: 12345 Typicalville 73 Since schedule not in effect until the next year! Chapter 9, PAR Guidance Pretreatment Performance Summary (PPS) 1.Pretreatment Town Name: 2."Primary" NPDES Number NC00 or Non_Discharge Permit # if applicable => 3.PAR begin Date, please enter 01/01/yy 3. =>1/1/2012 4.PAR end Date, please enter 12/31/yy 4. =>12/31/2012 5.Total number of SIUs, includes CIUs 5. =>3 6.Number of CIUs 6. =>1 7.Number of SIUs with no IUP, or with an expired IUP 7. =>0 8.Number of SIUs not inspected by POTW 8. =>0 9.Number of SIUs not sampled by POTW 9. =>0 10.Number of SIUs in SNC due to IUP Limit violations 10. =>2 11.Number of SIUs in SNC due to Reporting violations 11. =>1 12.Number of SIUs in SNC due to violation of a compliance schedule, CO, AO or similar 12. =>0 13.Number of CIUs in SNC 13. =>1 14.Number of SIUs included in public notice 14. =>2 15 Total number of SIUs on a compliance schedule, CO, AO or similar 15. =>0 16.Number of NOVs, NNCs or similar assesed to SIUs 16. => 17.Number of Civil Penalties assessed to SIUs 17. => 18.Number of Criminal Penalties assessed to SIUs 18. => 19.Total Amount of Civil Penalties Collected 19. => $ 20.Number of IUs from which penalties collected 20. => Foot Notes: 12345 Typicalville 74 Lines # 16, 17, 18 are based on number of events during PAR year, and do not include events occurring after PAR year. Chapter 9, PAR Guidance Pretreatment Performance Summary (PPS) 1.Pretreatment Town Name: 2."Primary" NPDES Number NC00 or Non_Discharge Permit # if applicable => 3.PAR begin Date, please enter 01/01/yy 3. =>1/1/2012 4.PAR end Date, please enter 12/31/yy 4. =>12/31/2012 5.Total number of SIUs, includes CIUs 5. =>3 6.Number of CIUs 6. =>1 7.Number of SIUs with no IUP, or with an expired IUP 7. =>0 8.Number of SIUs not inspected by POTW 8. =>0 9.Number of SIUs not sampled by POTW 9. =>0 10.Number of SIUs in SNC due to IUP Limit violations 10. =>2 11.Number of SIUs in SNC due to Reporting violations 11. =>1 12.Number of SIUs in SNC due to violation of a compliance schedule, CO, AO or similar 12. =>0 13.Number of CIUs in SNC 13. =>1 14.Number of SIUs included in public notice 14. =>2 15 Total number of SIUs on a compliance schedule, CO, AO or similar 15. =>0 16.Number of NOVs, NNCs or similar assesed to SIUs 16. =>16 17.Number of Civil Penalties assessed to SIUs 17. =>8 18.Number of Criminal Penalties assessed to SIUs 18. =>0 19.Total Amount of Civil Penalties Collected 19. => $ 20.Number of IUs from which penalties collected 20. => Foot Notes: 12345 Typicalville 75 Line # 19 is the actual amount in fines that was collected from the industries during this twelve month period. This can include collection of penalties assessed during prior reporting periods. Chapter 9, PAR Guidance Pretreatment Performance Summary (PPS) 1.Pretreatment Town Name: 2."Primary" NPDES Number NC00 or Non_Discharge Permit # if applicable => 3.PAR begin Date, please enter 01/01/yy 3. =>1/1/2012 4.PAR end Date, please enter 12/31/yy 4. =>12/31/2012 5.Total number of SIUs, includes CIUs 5. =>3 6.Number of CIUs 6. =>1 7.Number of SIUs with no IUP, or with an expired IUP 7. =>0 8.Number of SIUs not inspected by POTW 8. =>0 9.Number of SIUs not sampled by POTW 9. =>0 10.Number of SIUs in SNC due to IUP Limit violations 10. =>2 11.Number of SIUs in SNC due to Reporting violations 11. =>1 12.Number of SIUs in SNC due to violation of a compliance schedule, CO, AO or similar 12. =>0 13.Number of CIUs in SNC 13. =>1 14.Number of SIUs included in public notice 14. =>2 15 Total number of SIUs on a compliance schedule, CO, AO or similar 15. =>0 16.Number of NOVs, NNCs or similar assesed to SIUs 16. =>16 17.Number of Civil Penalties assessed to SIUs 17. =>8 18.Number of Criminal Penalties assessed to SIUs 18. =>0 19.Total Amount of Civil Penalties Collected 19. => $1,350 20.Number of IUs from which penalties collected 20. => Foot Notes: 12345 Typicalville 76 Line # 20 is the total number of industries that actually paid penalties during the year. Chapter 9, PAR Guidance Pretreatment Performance Summary (PPS) 1.Pretreatment Town Name: 2."Primary" NPDES Number NC00 or Non_Discharge Permit # if applicable => 3.PAR begin Date, please enter 01/01/yy 3. =>1/1/2012 4.PAR end Date, please enter 12/31/yy 4. =>12/31/2012 5.Total number of SIUs, includes CIUs 5. =>3 6.Number of CIUs 6. =>1 7.Number of SIUs with no IUP, or with an expired IUP 7. =>0 8.Number of SIUs not inspected by POTW 8. =>0 9.Number of SIUs not sampled by POTW 9. =>0 10.Number of SIUs in SNC due to IUP Limit violations 10. =>2 11.Number of SIUs in SNC due to Reporting violations 11. =>1 12.Number of SIUs in SNC due to violation of a compliance schedule, CO, AO or similar 12. =>0 13.Number of CIUs in SNC 13. =>1 14.Number of SIUs included in public notice 14. =>2 15 Total number of SIUs on a compliance schedule, CO, AO or similar 15. =>0 16.Number of NOVs, NNCs or similar assesed to SIUs 16. =>16 17.Number of Civil Penalties assessed to SIUs 17. =>8 18.Number of Criminal Penalties assessed to SIUs 18. =>0 19.Total Amount of Civil Penalties Collected 19. => $1,350 20.Number of IUs from which penalties collected 20. =>3 Foot Notes: 12345 Typicalville 77 78 Narrative Narrative •Recommended Outline for Narrative •Guidance is provided to: •Help you organize your PAR Narratives. •Help you determine what information is required or optional. •Help you understand how information is checked •Make it easier for us to find specific and useful information in the narratives. •Some information is optional. It has been noted or italicized in both the guidance text and in the examples. •This Guidance is available by e-mail, and on our web page. http://deq.nc.gov/about/divisions/water -resources/water-resources-permit-guidance/pretreatment -guide/annual-report-guidance 80 Outline of a Typical Narrative: 1 . General Information : A. General Program Information . B. General Permit Information . 2 . IU Information : A.IUs in SNC Information . B. Orders and Schedule Information (Please get this to us, we do need them). C. A to C and Construction Information. D. SIUs with Missing Data. Optional: E. Enforcement Actions by POTW, and Industry Responses, for Non -SNC, Non-Order, Non - construction events F. Other Information 81 Outline of a Typical Narrative (cont.): •If you have no IUs in SNC, on Orders, or having pretreatment construction activities, or missing data, your PAR Narrative may be as simple as the Division's two database items, with any corrections noted. •Program Information Sheet •Historical SNC database sheet(s) (not supplied for 2023 PAR) Still need all other required PAR forms for your type of Program – Full versus Modified Programs! 82 Description of Narrative details: General Information: A. General Program Information: 1. Pretreatment Program Info. Sheet (provided to you by the Pretreatment Staff with the end-of -year emailing) Status of Major Pretreatment Program Elements - LTMP/STMP, HWA, ERP, SUO, IWS - Are the dates and information correct, especially due dates? Include any needed corrections marked on the Info Sheet returned with the PAR Note, copies of the Program Info. Sheet are available upon request from the Pretreatment Staff. 2. Discuss Planned updates of major local program elements in narrative. 83 Description of Narrative details: General Information: B. Permit(s) General Information: 1. Did you have any permits expire before being renewed? LIST THEM, & WHY. 2.Did you have any SIU Permits that were Brand New, Dropped, or Changed Names during the Year? Please list them. 3.This is a good time to confirm that all issued IUPs have been received and reviewed by the Central Office. 84 Description of Narrative details: General Information: B. Permit(s) General Information (cont.): Optional Dates for these permit actions may be listed here as useful reference. We realize that some or all of these dates will have already been submitted to the Division with permit renewals, modifications, and drops. If you have permits that have been submitted to the Division and you have not received review letter back from the Division, you may note that here. For new permits, when did the permit become effective and when did the SIU actually begin discharge? Note, if a lag between these dates results in "missing" data, it must be explained (see "Missing" Data section below). 85 Description of Narrative details: IU INFORMATION : Please LIST alphabetically by IU name: A . IUs in SNC Information: 1 . All IUs in SNC MUST be included in the Narrative and listed on the SNCR Form! 2. Note the reason(s) and which six-month period(s) they were in SNC . 3. If SNC for limits, note if was due to chronic, TRC, or both. Information should match what is on your IDSF and SNCR Forms. 4. If SNC for something other than limits, such as: reporting, missing data/self monitoring, interference, pass-through, permit conditions, etc. please explain. 86 Description of Narrative details: IU INFORMATION: A . IUs in SNC Information: (cont.) 5. Enclose a copy of the Public Notice for SNC, or affidavit. If Public Notice is not in the PAR explain why not. PAR will not be considered complete until Public Notice is received. 6. Explain how a SNC situation was or will be resolved; such as: increased limit, shut down, installed or improved pretreatment, better operations, production changes, etc. 7. Explain how previous SNC situations were resolved if resolution occurred in this PAR year. 87 Description of Narrative details: IU INFORMATION: (cont.) B. Orders or Schedule Information: For SIUs on an Order of any kind (including Administrative Orders, Consent Orders, Compliance Schedules) at any time during the PAR year, include the following information : 1 . A copy of the Order/Schedule with the PAR. If Order/Schedule has been modified since last submitted, include a new copy with the PAR. 2. Notes on all successfully completed Orders/Schedules. 3. Notes on all due dates in the Order/Schedule. 4. Notes on violations of any interim limits or due dates. Explain what and why and discuss penalties assessed and penalties collected. You may (optional) attach copies of NOVs and correspondence. 5. The Division might request a separate copy of the Administrative Orders, Consent Orders, and/or Compliance Schedules. 88 Description of Narrative details: IU INFORMATION (cont.): C. Pretreatment (A -to-C) and Construction Info: 1 . Narrative must include information on any SIUs who have submitted plans and specifications, requested an A -to-C, or had construction activities on their pretreatment systems during the PAR year. This information will document or measure improvements to pretreatment facilities and the work of pretreatment coordinators toward improving the environment. 2.Please include the following information: a. Brief description of what is, was, or will be constructed. b. Approx. cost. c. Date submitted and/or date of A -to-C. d. Date construction began, or is scheduled to begin. e. Date construction completed or scheduled to end. 89 Description of Narrative details: IU INFORMATION (cont .): D. SIUs with Missing Data: 1 . Explain WHY any required sampling may "appear" to have not been done for any SIU. Missing data may be required to be repeated . Missed self-monitoring is a violation and may be considered SNC. Some reasons for missing data are: A permit is issued (became effective) well before the actual discharge begins. A Permit is officially dropped well after the actual discharge was stopped. Temporary shut downs / No process discharge. Missed self monitoring, "botched" sampling, act of god, act of nature, or other reason. (EXPLAIN !) 90 Description of Narrative details: IU INFORMATION (cont.): OPTIONAL: E.POTW Enforcement Actions and SIU Response Information, for Non-SNC, Non -Order, Non- Construction, Non-missing data events: 1 . Enforcement actions taken by the POTW, may include NOVs, meetings, extra inspections, increased monitoring, penalties assessed, and penalties collected. Note, assessing penalties and collecting penalties should be documented as separate actions. 2. Briefly explain how SIU responded to the enforcement action(s). Information such as any known cause for the violations, and what the SIU has done or is doing to correct the problem. Did the SIU deny the problem, request a meeting, appeal the NOV, etc.? 91 Description of Narrative details: IU INFORMATION (cont .): OPTIONAL: F. Other Information: 1 . Information on SIUs with minor violations may be listed in the narrative very briefly. This may be general and does not have to list the specifics about limits violations (note, the percent violations is already summarized on the IDSF form). Minor violations can be an indicator of future major violations. 2. Any other information you think is important. 92 Narrative - Example: Town of Typicalville (NPDES #NC0012345) 2013 PAR Narrative GENERAL INFORMATION: GENERAL PROGRAM INFORMATION: •AT, LTMP, HWA, SUO, ERP, IWS, and Permits are up to date. You can explain the status of these program elements in regard to DWR’s review. •Are all Dates on the Division's Database Program Info Sheet correct? •A copy of our Program Info sheet is enclosed with corrections. •Optional reporting of voluntary emerging compound information on a spreadsheet (provided by the Division upon request). 93 Narrative - Example: Town of Typicalville (NPDES #NC0012345) 2013 PAR Narrative GENERAL INFORMATION (cont.): GENERAL PERMIT INFORMATION: •No permits lapsed or expired prior to renewal •No new or Name Changes at any SIUs 94 Narrative - Example: Town of Typicalville (NPDES #NC0012345) 2023 PAR Narrative Slugem Hosiery Mill, Inc. (IUP # 0007, Textile) SNC INFORMATION: •SIU was not in SNC this PAR Year •Previous SNC situation, see 2022 PAR, was resolved with permit modification effective February 1, 2023. The POTW increased IUP limits for chromium and copper. The cause of the violations and SNC in 2022 was determined to be increased production and flow. ORDERS AND SCHEDULE INFORMATION: None A to C and CONSTRUCTION INFORMATION: None MISSING DATA: Please note there is no monitoring for ammonia, mercury, or MBAS for the first six months as this is only an annual monitoring requirement 100 Narrative - Example: Town of Typicalville (NPDES #NC0012345) 2023 PAR Narrative •Slugem Hosiery Mill, Inc. (IUP # 0007, Textile) - Cont. OPTIONAL: • ENFORCEMENT ACTIONS by POTW, and Industry responses for Non-SNC, Non-Order, Non -Construction, Non -"missing" data events: •The $500 penalty ($250 per SNC) assessed in the last PAR Year (2022) was paid on February 22, 2023. •There were also two reporting violations for late sample reporting (two weeks late for March and 8 days late for October). NOVs were issued and penalties were assessed at ($50 each). Penalties were paid on May 5, and November 30, respectively. •Overall, this Industry has been very cooperative with the Town in resolving all issues. •A couple of limit violations occurred in 2023, (see IDSF form, NOVs were issued), but overall the SIU was not in SNC for either six month period in 2023. 101 Narrative - Example: Town of Typicalville (NPDES #NC0012345) 2023 PAR Narrative •Terrible Textiles. (IUP # 0009) •As noted in the 2023 PAR, Terrible Textiles burned down on 12/1/2022 and the permit was formally dropped effective 12/31/2022. There was no monitoring, no data, and therefore no IDSF for this industry in this PAR. 102 Narrative - Example: Town of Typicalville (NPDES #NC0012345) 2023 PAR Narrative •Will Plateit Metal Finishers, Inc. (IUP # 0006, 40CFR433) SNC INFORMATION: •This SIU was in SNC for the parameter of Cadmium (Cd) for both the January 1-June 30, 2023, and the July 1-December 31, 2023, reporting periods . •SIU was SNC for two periods in a row for Cadmium. •In general, this Industry cannot identify or resolve the cause of their SNC. They also do not promptly pay the penalties. Several meetings between the Town and the Industry, as well as letters from our attorney have improved the industry’s cooperation, but have still been unable to determine the source or reason for the increased Cadmium levels. Consent Order issued to require resolution, with upfront penalty. •Copy of Public Notice is enclosed. 103 Narrative - Example: Town of Typicalville (NPDES #NC0012345) 2023 PAR Narrative •Will Plateit Metal Finishers, Inc. (IUP # 0006, 40CFR433) – Cont. ORDER/SCHEDULE INFORMATION: •POTW and the SIU entered into a Consent Order (copy enclosed). Effective date of 2024, so not included on the PPS form. A-to-C and CONSTRUCTION INFORMATION: None MISSING DATA: NONE Optional - OTHER MISC. INFORMATION: •The SIU filed both required semi-annual TTO certifications in lieu of monitoring for organics. TOMP is active and updated. 104 Narrative - Example: Town of Typicalville (NPDES #NC0012345) 2023 PAR Narrative •Will Plateit Metal Finishers, Inc. (IUP # 0006, 40CFR433) – Cont. OPTIONAL: • ENFORCEMENT ACTIONS by POTW, and Industry responses, for Non- SNC, Non-Order, Non-Construction, Non-"missing" data events: •Several other NOVs were issued throughout the year. •A penalty of $250 was issued for the Jan-Jun 2023 SNC. SIU failed to pay the penalty within the required 30 days. It was paid on September 30, 2023 after a strong letter from the POTW’s attorney indicating failure to pay would result in termination of service. •Another $1000 penalty for the Jul-Dec SNC was incorporated into the Consent Order. It has not been collected, but documentation of collection will be included in our next PAR. 105 No Corrections Needed. 106 Waste Reduction: Per .0916 of the Rule and G.S 143-215.1(g), required only to be submitted with IUP applications. No longer required for the PAR! Public Notice Public Notice •Required to be done a minimum of once per year •What is in your SUO? •Largest Daily Newspaper Circulated in Area? •Newspaper of General Circulation that provides meaningful public notice? •Generally completed in January or February for all SNC for Previous Year and Included in PAR due March 1; •Optional to complete Public Notice after each six month period, i.e., in July or August for January through June SNCs, and again in January or February for July through December SNCs •may help SIU relations for SIUs in SNC for January through June for the POTW to issue Public Notice while problem is on -going instead of 6 months or more after they have fixed the problem 109 Public Notice (cont.) •Public Notice Must Include All IUs in SNC due to Limits Violations or Reporting or IUP Condition Violations •Along with the IU Names, the Public Notice should include: •Periods of SNC (January - June or July –December) •the Parameter(s), Reporting, or Specific IUP Condition •OPTIONAL: any other discussion you want, for example how the SNC did not affect your WWTP or the environment, or how hard the SIU has worked to fix the problem, or how their negligence caused the problem in the first place, or how uncooperative they have been 110 Public Notice (cont.) •In PAR, either include Affidavit provided by Newspaper, or cut out the Public Notice from the newspaper (make sure the piece of the newspaper is large enough to include the Public Notice and the part of the page with the name of the paper and the date. •If unable to include Public Notice in PAR, explain in the narrative why it couldn’t be done earlier. Submit Copy of Affidavit or cut out from Newspaper ASAP. NOTE: PAR will not be considered complete until Public Notice is received. Can be accepted as a supplemental document to the PAR. 111 PUBLIC NOTICE OF SIGNIFICANT INDUSTRIAL WASTEWATER PERMIT VIOLATIONS The Town of Typicalville, in accordance with Federal and State Regulations is hereby giving Public Notice. Listed below are Significant Industrial Users that were in significant noncompliance (SNC) with national pretreatment regulations, 40 CFR Part 403, and state pretreatment regulations, 15 NCAC 2 H .0900, and local pretreatment regulations during the period of January 1 thru June 30, 2012; Will Plateit Metal Finishers, Inc.- Cadmium. And July 1 thru December 31, 2012; Will Plateit Metal Finishers, Inc.- Cadmium A continuing effort is being made by all the listed industries to achieve compliance, including installation of new equipment and upgrading of existing equipment and continued progress is expected until full compliance can be attained. Town of Typicalville, Department of Public Utilities, Jane Wastewater, Director. January 17, 2013 Affidavit of Publication The Typicalville Herald Typicalville, N.C. Personally appeared before me, a Notary Public of the County of Typical, State of North Carolina, on this the __17__day of ______January_____2013 _____Suzy Newsy_____ of The Typicalville Herald, who, bring duly sworn, state that the notice entitled PUBLIC NOTICE OF SIGNIFICANT INDUSTRIAL WASTEWATER PERMIT VIOLATIONS _______________________________________ a true copy of which is attached hereto, appeared in The Typicalville Herald, a newspaper published in the Town of Typicalville, County of Typical, State of North Carolina, _____once____ a week for _____one____week(s), on the following dates: January 17___________ ______20___13_ ______________________________20______ ______________________________20______ ______________________________20______ _______________________________________ The Typicalville (N.C.) Herald of ______January___________2013 ____Peter Public___ Notary Public 112 Enforceable Compliance Schedules Enforceable Compliance Schedules •Two basic kinds •Signed by both POTW and SIU: Consent orders, Compliance Agreements, SOCs, etc,; •Signed by POTW only: Administrative Orders •either when SIU refuses to agree to an order, or when SIU has failed to comply with original “consent” type order 114 Enforceable Compliance Schedules (cont.) •When to issue •Issued when SIU will be in SNC for second period in a row for same parameter/reporting violation •Can be issued earlier to help SIU avoid further violations (i.e. if you already know the violations will continue and you have a good idea of the steps the SIU must take to comply, then why wait to issue the order?) 115 Enforceable Compliance Schedules (cont.) •What’s in it •Up-front penalties to address violations up to the time of issuance of order. •Interim limits SIU can comply with, i.e., gets SIU back in “compliance” temporarily. These limits supersede IUP limits during term of order. These limits are the SIU’s “carrot.” •Interim limits can be higher than categorical limits •No over allocation without prior DWR approval 116 Enforceable Compliance Schedules (cont.) •What’s in it (cont.) •Schedule of items, each with a specific due date, that SIU will complete in order to return to compliance with original/final IUP limits. This is the POTW’s “carrot,” i.e. commitment from SIU to do specific things by specific dates. •Specific items can vary greatly from SIU to SIU, and should be developed for each specific circumstance •Stipulated penalties for violations of conditions in order (limits, due dates, etc.). This is POTW’s “stick.” 117 North Carolina County of Typical In the matter of Town of Typicalville Pretreatment Permit No. 0006 held by Will Plateit Metal Finishers, Inc. CONSENT ORDER AND COMPLIANCE SCHEDULE Pursuant to provisions of the Sewer User Ordinance of the Town of Typicalville, this Consent Order is made effective the 1st day of February, 2023, between Will Plateit Metal Finishers, Inc . (hereinafter the "User") and the Town of Typicalville (hereinafter the "Town"). The User and Town hereby stipulate and agree as follows: 1. User holds Town of Typicalville Pretreatment Permit No. 0006 (hereinafter the "Permit", which shall refer to User's existing permit and any subsequent renewals or modifications thereof) for the operations of existing pretreatment units and discharges from said treatment works into the Town's sewer system. 2. User has been unable to meet the permit limitations for Cadmium (Cd) set forth in its Permit. 3. Achievement of these limits will require resolution of existing problems in the present treatment train and possibly, development of alternative solutions to alleviate noncompliance, including but not limited to the construction of additional pretreatment facilities as well as the preparation of plans and specifications as necessary. 4. User hereby agrees to do and perform all of the following: 118 a.Meet and comply with all terms and conditions of the Permit (except as modified by the Order) provided, however, subject to the terms and conditions of the Consent Order, the following shall apply: Parameter Daily Max (mg/L) Monitoring Frequency Detection Limit Cadmium (Cd) 0 .13 Weekly 0.002 mg/L b.Unless and until Compliance is achieved, the User will undertake activities necessary to bring the User into Compliance in accordance with the following schedule: •COMPLIANCE SCHEDULE Deadline for Completion April 1, 2023 July 1, 2023 September 1, 2023 December 1, 2023 March 1, 2024 June 1, 2024 July 1, 2024 Activities (i)Prepare an Engineering Report of process alternatives and/or pollution prevention/waste minimization alternative designed to achieve Compliance (ii)Complete Pilot Studies or waste minimization studies and identify alternatives chosen to achieve Compliance (iii)If required, submit necessary drawings and information to obtain any necessary permits and/or authorization to construct from the Town of Typicalville (iv)Begin construction and/or implement identified process alternative(s), pollution prevention, and waste minimization alternatives. (v)Complete identified construction/pollution prevention/ waste minimization alternatives and/or process alternatives. (vi)Complete analysis of implemented changes, including daily monitoring from April 1 st to May 1st and make necessary modifications to optimize and obtain full operational status. (vii)Achieve compliance with final (IUP) limit 0.07 mg/L.119 c. User shall perform each of the activities set forth in subparagraph (b) on or before the dates established thereby unless such dates are extended by agreement of User and the Town. The User may request such extensions for good cause, and the Town will not unreasonably withhold its consent to such extension. d. User shall submit a comprehensive written report within five (5) days following each milestone date specified in subparagraph (b). Each such report shall be in narrative form, shall state in detail the activities undertaken since the last report to achieve Compliance, and shall indicate whether User has met the due date for the relevant milestone established in this Consent Order. If any report contains notice of failure to meet a milestone date, the report shall also include a statement explaining the cause of the failure, any remedial actions taken, and the probability of meeting the next milestone. During any period of construction, User shall submit on or before the 10th day of each month, detailed construction progress reports stating therein in narrative form the work performed during the month and the percentage of completion of the project. All reports required by the Consent Order shall be submitted to the Town by Certified Mail, Return Receipt Requested, addressed to: Director of Public Utilities Town of Typicalville PO Box 123 Typcialville, NC 12345 e. The User shall pay the Town $1,000, no later than February 27, 2023, for the Significant Non- Compliance during the July through December 2022 reporting period. 120 f. Any violation of the terms of this Consent Order shall subject the User to the enforcement authority outlined in the Ordinance. Such action may include, but is not limited to such fines, penalties and assessments as may be set forth in the Code of Ordinance of the Town of Typicalville, as amended from time to time. g. In lieu of other penalties, the following stipulated penalties shall apply for violations of the User's limits or failure to meet a milestone date under this Consent Order, or failure to achieve full compliance with Consent Order. Violation of limits $200 per day, per violation Failure to collected required samples, meet compliance schedule deadlines, required reports, or other milestone dates contained herein $200 per day, per violation Failure to achieve full compliance with Final IUP limit at expiration of Order $1,000 per day 121 h. Once Compliance is achieved, this Consent Order shall terminate and all obligations hereunder except any obligation to pay identified moneys to the Town shall expire. Upon termination of this Order, the User shall be subject to all terms of the Permit. i. In the performance of activities under this Consent Order, User must otherwise follow the procedures, rules, regulations, ordinances, and statutes of the Town, State, and Federal governments as they may apply to User. Nothing contained herein shall be construed as a waiver thereof by the Town. Signed on this 26th day of January 2023. USER:Will Plateit Metal Finishers, Inc. BY: William B Plateit TITLE: President TOWN:Town of Typicalville BY: Jane Wastewater TITLE: Director of Public Utilities This Order expires July 11, 2024. 122 Allocation Tables (ATs) •Should be current as of December 31st, the last day of the end of the PAR Reporting Period •Includes Effective and Expiration Dates; May Include Permit Modification Date(s) •Includes Permit Limits For Each SIU and Pipe •Includes Information from Headworks Analysis (HWA) •MAHL •Uncontrollable Loading •MAIL Do YOU have any Over Allocations??? – Explain in Narrative! 123 Allocation Table Headworks last approved:7/12/12 Town of Typicalville Allocation Table updated:9/30/12 NC0012345 Permits last modified:9/30/12 Most Recent INDUSTRY Industry Type Original Modification Date Permit Limits Permit Limits Permit Limits IUP NAMES Permit/Pipe of Effective Effective Permit Conc.Load Conc.Load Count (please list alphabeticly)number Industry Date Date Expires MGD gal/day mg/l lbs/day mg/l lbs/day 1 Chicken Pluckers, Inc.0008/01 poultry 6/30/11 9/30/12 12/30/15 1.0000 1,000,000 300 2502 300 2502 2 Slugem Hosiery Mill, Inc.0007/01 dye and finish 6/30/11 2/1/12 12/30/15 0.3600 360,000 300 901 300 901 3 Will Plateit Metal Finishing, Inc.0006/01 433-metal finishing 6/30/11 12/30/15 0.0980 98,000 4 Column Totals =>1.4580 1,458,000 3403 3403 npdes npdes(5 mg/l) MAHL from HWA (lbs/day) =>5.0000 9800 19599 Uncontrollable Loading (lbs/day) =>1.8900 2115 3214 Total Allowable for Industy (MAIL) (lbs/day)=>3.1100 7685 16385 Total Permitted to Industry (lbs/day) =>1.4580 3403 3403 MAIL left (lbs/day) =>1.6520 4282 12983 Percent Allow. Ind. (MAIL) still available (%) =>53.1 %55.7 %79.2 % Percent MAHL still available (%) =>33.0 %43.7 %66.2 % 5 Percent MAHL (lbs/day) =>0.2500 489.98 979.95 FLOW BOD TSS Total Allowable for Industry is also known as Maximum Allowable Industrial Load or MAIL Allocation Tables (ATs) 124 Allocation Tables (ATs) (cont.) 125 Allocation Table Town of Typicalville NC0012345 INDUSTRY Industry Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits IUP NAMES Permit/Pipe Conc.Load Conc.Load Conc.Load Conc.Load Conc.Load Conc.Load Count (please list alphabeticly)number mg/l lbs/day mg/l lbs/day mg/l lbs/day mg/l lbs/day mg/l lbs/day mg/l lbs/day 1 Chicken Pluckers, Inc.0008/01 monitor 2 Slugem Hosiery Mill, Inc.0007/01 0.5000 1.5012 0.6000 1.8014 3 Will Plateit Metal Finishing, Inc.0006/01 0.0700 0.0572 1.7100 1.3976 2.0700 1.6919 0.0100 0.0082 4 Column Totals =>0 0 0.0572 2.8988 3.4933 0.0082 npdes MAHL from HWA (lbs/day) =>784 1.5679 0.1048 3.9198 6.2717 0.2630 Uncontrollable Loading (lbs/day) =>243 0.0226 0.0226 0.3770 0.8746 0.0377 Total Allowable for Industry(MAIL) (lbs/day) =>541 1.5453 0.0822 3.5428 5.3971 0.2253 Total Permitted to Industry (lbs/day) =>0 0.0000 0.0572 2.8988 3.4933 0.0082 MAIL left (lbs/day) =>541 1.5453 0.0250 0.6440 1.9038 0.2171 Percent Allow. Ind. (MAIL) still available (%) =>100.0 %100.0 %30.4 %18.2 %35.3 %96.4 % Percent MAHL still available (%) =>69.0 %98.6 %23.8 %16.4 %30.4 %82.6 % 5 Percent MAHL (lbs/day) =>39.20 0.0784 0.0052 0.1960 0.3136 0.0132 COPPER CYANIDEAMMONIAARSENICCADMIUMCHROMIUM Total Allowable for Industry is also known as Maximum Allowable Industrial Load or MAIL Allocation Tables (ATs) (cont.) 126 Allocation Table Town of Typicalville NC0012345 INDUSTRY Industry Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits IUP NAMES Permit/Pipe Conc.Load Conc.Load Conc.Load Conc.Load Conc.Load Conc.Load Count (please list alphabeticly)number mg/l lbs/day mg/l lbs/day mg/l lbs/day mg/l lbs/day mg/l lbs/day mg/l lbs/day 1 Chicken Pluckers, Inc.0008/01 monitor 2 Slugem Hosiery Mill, Inc.0007/01 monitor 0.6500 1.9516 3 Will Plateit Metal Finishing, Inc.0006/01 0.4300 0.3514 0.0002 0.00016 2.3800 1.9452 30.00 24.52 0.2400 0.1962 1.4800 1.2096 4 Column Totals =>0.3514 0.00016 1.9452 24.52 0.1962 3.1612 npdes(summer) MAHL from HWA (lbs/day) =>1.0453 0.00047 2.6244 239.00 3.9198 7.8396 Uncontrollable Loading (lbs/day) =>0.3317 0.00226 0.1583 66.49 0.0377 0.9424 Total Allowable for Industry (MAIL) (lbs/day) =>0.7136 -0.0018 2.4661 172.51 3.8821 6.8972 Total Permitted to Industry (lbs/day) =>0.3514 0.00016 1.9452 24.52 0.1962 3.1612 MAIL left (lbs/day) =>0.3622 -0.00196 0.5209 147.99 3.6859 3.7360 Percent Allow. Ind. (MAIL) still available (%) =>50.8 %109.1 %21.1 %85.8 %94.9 %54.2 % Percent MAHL still available (%) =>34.6 %-416.1 %19.8 %61.9 %94.0 %47.7 % 5 Percent MAHL (lbs/day) =>0.0523 0.0000 0.1312 11.95 0.1960 0.3920 LEAD MERCURY NICKEL Phosporous SILVER ZINC Total Allowable for Industry is also known as Maximum Allowable Industrial Load or MAIL See narrative for resolution of mercury over allocation. Allocation Tables (ATs) (cont.) 127 Allocation Table Town of Typicalville NC0012345 INDUSTRY Industry Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits IUP NAMES Permit/Pipe Conc.Load Conc.Load Conc.Load Conc.Load Conc.Load Count (please list alphabeticly)number mg/l lbs/day mg/l lbs/day mg/l lbs/day mg/l lbs/day mg/l lbs/day 3 Chicken Pluckers, Inc.0008/01 75 626 2 Slugem Hosiery Mill, Inc.0007/01 monitor monitor 1 Will Plateit Metal Finishing, Inc.0006/01 4 Column Totals =>626 0.0000 0.0000 0.0000 MAHL from HWA (lbs/day) =>2036 63.7366 3.0044 0.1730 Uncontrollable Loading (lbs/day) =>109 16.0739 Total Allowable for Industry (MAIL) (lbs/day) =>1927 47.6627 3.0044 0.1730 Total Permitted to Industry (lbs/day) =>626 0.0000 0.0000 0.0000 MAIL left (lbs/day) =>1302 47.6627 3.0044 0.1730 Percent Allow. Ind. (MAIL) still available (%) =>67.5 %100.0 %100.0 %100.0 % Percent MAHL still available (%) =>63.9 %74.8 %100.0 %100.0 % 5 Percent MAHL (lbs/day) =>101.81 3.1868 0.1502 0.0087 OtherMolybdenumSeleniumMBASOil & Grease Total Allowable for Industry is also known as Maximum Allowable Industrial Load or MAIL Do you have good news? Please share with us! We would love to hear from you. 128 PARs due MARCH 1 NC DIVISION OF WATER RESOURCES NPDES Municipal Permitting Section 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-1617 Send a Copy (Please send to Central Office in Raleigh...We forward the copy to the Region.) 129 Division Pretreatment Contacts Al Woodall: (919) 707 -3608 Octavio Henriquez: (919) 707 -3662 Natalie Gorensek: (919) 707 -3660 Keyes McGee: (919) 707 -3626 Email: firstname.lastname@deq.nc.gov Physical Address: 1617 Mail Service Center Raleigh, NC 27699 -1617 Website: https://deq.nc.gov/about/divisions/water -resources/water -quality-permitting/municipal -npdes-pretreatment -and -collection-system/pretreatment 130