HomeMy WebLinkAbout20. 18-558 NOVEMBER 14, 2018 18-558 RESOLUTION
(CARRIED 6-0 LOST LAID OVER WITHDRAWN )
PURPOSE: ADOPT CITY OF OSHKOSH INDUSTRIAL WASTEWATER
DISCHARGE PROGRAM HANDBOOK
INITIATED BY: DEPARTMENT OF PUBLIC WORKS
WHEREAS, the City of Oshkosh Wastewater Treatment Plant operates under a
Wisconsin Pollutant Discharge Elimination System (WPDES) permit issued by the
Wisconsin Department of Natural Resources (WDNR); and
WHEREAS, one of the requirements of the permit is an Industrial Pretreatment
Program; and
WHEREAS, review and updating of the City's wastewater ordinance and pre-
treatment handbook establishing and implementing the Industrial Pretreatment Program
have been completed and have been reviewed and approved by WDNR.
NOW, THEREFORE, BE IT RESOLVED by the Common Council of the City of
Oshkosh that the attached City of Oshkosh Industrial Wastewater Discharge Program
Handbook is hereby approved and adopted for Industrial Users discharging to the City
of Oshkosh Wastewater Treatment System.
City
of
Oshkosh
MEMORANDUM
TO: Honorable Mayor and Members of the Common Council
FROM: Stephan M. Brand, Public Works Utility Bureau Manager,)
DATE: November 8, 2018
RE: Adopt City of Oshkosh Industrial Wastewater Discharge Program Handbook
BACKGROUND
The Wisconsin Department of Natural Resources (WDNR), through an agreement with the
United States Environmental Protection Agency (EPA), is responsible for permitting and setting
regulatory requirements for municipal wastewater treatment systems. These requirements are
completed through the issuance of system -specific Wisconsin Pollutant Discharge Elimination
System (WPDES) permits. One of the required elements of the WPDES Permit for communities
with a treatment plant flow of over five million gallons per day is to have an Industrial Pre -
Treatment Program. The City of Oshkosh implements these requirements within Chapter 24 of
the Municipal Code of the City of Oshkosh.
In 2014, the WDNR updated its program to reflect updates and changes made by the EPA. The
WDNR provided information on the program changes to communities so the communities could
have these new requirements included within their local ordinances. Prior to implementing those
revisions, the Wastewater Utility completed a local limits study to determine if any changes were
necessary to the treatment requirements for industries regulated by the pre-treatment program.
Sampling was completed in 2016, and the final report was issued in 2017. The revised program
was submitted to the WDNR for their review and was approved in February 2018. The final
reading of the ordinance to update Chapter 24 is also on the agenda for consideration. That
update includes the WDNR-approved revisions to the City's program. With the updates to
Chapter 24, revisions to the City of Oshkosh Industrial Wastewater Discharge Program
Handbook were required to maintain consistency.
ANALYSIS
Wastewater Utility staff worked with the City Attorney's office to incorporate the revisions
necessary to be consistent with the WDNR-approved program, along with editorial changes to
improve clarity. The changes to the Industrial Wastewater Discharge Program Handbook reflect
the updates made in Chapter 24.
L\ Engineering \Tracy Taylor\ Memos to Mayor & Common Council \ 2018 \Pre -Treatment Handbook\ Ind Page 1 Of 2
WW Discharge Prog Handbook_11-8-18.doc
FISCAL IMPACT
There are no budgetary impacts associated with these changes.
RECOMMENDATIONS
I recommend adopting the City of Oshkosh Industrial Wastewater Discharge Program
Handbook.
Approved,
Mark A. Rohloff
City Manager
SMB/t1t
l: \ Engineering\Tracy Taylor\Memos to Mayor & Common Council\2018\Pre-Treatment Handbook\Ind Page 2 0f Z
WW Discharge Prog Handbook_11-8-18.docx
b�
City
of�
Oshkosh
CITY OF OSHKOSH
INDUSTRIAL WASTEWATER DISCHARGE PROGRAM
HANDBOOK
Adopted November 14, 2018
Table of Contents
Chapter 1 - Introduction, Summary, and Program Administration
3
Introduction
3
Summary of Program
3
General
3
Industrial User Survey
4
Analysis of Technical Information
4
Industrial Monitoring Program
4
Financial Program
5
Checklists, Forms, and Worksheets
6
Program Administration
6
Organization
6
Legal Authority
6
Program Operation
7
Definitions
11
Chapter 2 - Industrial Monitoring Program
17
Introduction
17
Monitoring Methods and Procedures
17
Significant Industrial User Notification
17
Sampling Procedures
18
Significant Industrial User Inspection and Sampling
18
Chain of Custody
19
Analytical Procedures
20
Safety Procedures
20
Right -of -Entry
20
Enforcement Standards and Requirements
20
Monitoring Program
21
EPA Point Source Categorical Pre -Treatment Standards
22
Interpretation of Monitoring Program Results
22
Monitoring Program Updating Procedure
22
Chapter 3 - Financial Program
25
Introduction
25
Individual Industry Cost
25
Administrative Costs
25
Chapter 4 - References, Regulations, Standards, and Ordinances
27
Chapter 5 - Enforcement Response Plan
28
Introduction
28
Definition of Enforcement Responses
29
1
Investigation of Noncompliance 30
Enforcement Response Guide 30
Chapter 6 — Forms 41
Pre -Treatment Industrial User Survey Questionnaire 42
Baseline Report 62
Industrial Wastewater Discharge Permit Application 66
Industrial Inspection Survey 69
90 -Day Final Compliance Report 73
Sample Audit Sheet 74
Chapter 1. Summary and Program Administration
INTRODUCTION
The City of Oshkosh completed construction of a 20 million gallon per day (MGD)
wastewater plant (WWTP) in 1975. Several upgrades to the plant have been made since
then, including switching to Fine Bubble Aeration for secondary treatment, and the
addition of an Anaerobic Digestion process for volatile solids reduction and
accompanying centrifuge for dewatering the sludge. Also, the plant has added backup
generators for auxiliary power. The maximum pumping capacity of the plant is 100
MGD. The daily design flow is 20 MGD, and the average dry weather flow at the plant
is about 12 MGD. Wastewater is collected and treated by means of an activated sludge
process. Wastewater flow is also received from the Town of Algoma and the Town of
Slack Wolf. Neither currently has any industrial contributors.
The treatment plant has not experienced any problems in meeting its discharge permit
limitations. On occasion, influent concentrations of the conventional pollutants,
Biochemical Oxygen Demand (SOD), Suspended Solids (SS), Ammonia, and Phosphorus
have been higher than normal; however, the overall performance of the facility has not
been affected. There have been no plant upsets, and no significant problems exist with
the treatment of wastewater or sludge handling. The sludge is dewatered, hauled, and
spread on agricultural land in the area by a contractor.
Plant effluent is discharged to the Fox River near Lake Winnebago. There are known
problems with the collection system which are currently being studied, including Inflow
and Infiltration (I/I). The major problem is the deterioration of the concrete piping from
the formation of Hydrogen Sulfide. It is believed this may be attributable to the discharge
from the Winnebago County Landfill, which is in the Industrial Pre -Treatment Program.
SUMMARY OF PROGRAM
General
The Oshkosh Industrial Wastewater Discharge Program has been designed, and will be
implemented, so as to accomplish the following objectives:
• To comply with State and Federal rules and regulations which require the
establishment of an equitable and implementable industrial program which
ensures compliance by industry with the EPA pre-treatment regulations.
3
• To establish and continue to update a database which provides pertinent
information about each industrial process which discharges into the City's
sewer system.
• To establish and update a technical database from which the City can control
and enforce requirements in its sewer use ordinance which regulates the
discharge of prohibited substances to the City's sewer system.
• To periodically establish correct wastewater service charges and industrial
wastewater discharge program charges.
• To assist industries in meeting their NR 101 reporting requirements.
• To equitably distribute the costs associated with this program to the affected
industries.
The following sections briefly describe how the procedures contained in this Handbook
will result in the City meeting these objectives.
Industrial User Survey
The results of the initial industrial survey were generated by mailing each identified
industry a questionnaire and following up with those in question with a baseline report
form. A field inspection of all industries in question resulted in the issuance of discharge
permits to all significant industries identified. Annual review of directories and continual
monitoring of new construction allows for updating this list of significant industries and
industry in general.
Analysis of Technical Information
The analysis of technical information is directed toward the establishment of limits for
prohibited substances in the Oshkosh sewer use ordinance, updating procedures which
include periodic monitoring at the WWTP, are intended to detect influent and effluent
problems, to detect developing trends which could be problems, and to provide a basis
for adjustment and enforcement of pollutant limits listed in the City's ordinance.
Industrial Monitoring Program
The industrial monitoring program procedures are designed to accomplish four
objectives:
4
• To ensure certain industries are in compliance with the reporting and effluent
requirements of the EPA's point source categorical pre-treatment standards
regulations.
• To assist selected industries in preparing NR 101 reports.
• To provide data for the City's user charge program.
• To ensure compliance with the prohibited substances discharge limits
contained in the City's sewer use ordinance.
Administration of the monitoring program will be done by City personnel. Actual
sampling and monitoring will be done by a State -certified laboratory. Most monitoring
will occur quarterly.
Financial Program
The financial program has two objectives. The first is to ensure the entire program is
performed in as cost effective a manner as can be achieved. The second is to ensure all
program costs are borne by the affected industries.
The financial program is split into two parts. The first part deals with direct costs
attributable to each industry. These include sampling and analysis costs, special
consultant and legal costs, permit fees, and other direct costs. All of these costs are to be
billed to the industries semi-annually (April and October).
The second part consists of general program administrative costs. These include program
sampling and analysis costs at the WWTP, consultant costs, and other costs. These
administrative costs are apportioned to each industry on the basis of that industry's
estimated direct costs for the next year. This amount is then billed in the April and
October invoices. Prior to the next year's April invoice, an audit is performed, and the
actual administrative costs are re -apportioned to each industry on the basis of that
industry's actual direct cost in the preceding year. An adjustment is then made to the
new April billing invoice.
5
Checklists, Forms, and Worksheets
Chapter 6 contains all of the forms used to administer this program.
PROGRAM ADMINISTRATION
Organization
The Director of Public Works will have the overall responsibility for the Industrial
Wastewater Discharge Program; the program coordinator will be the City's Pre -
Treatment Coordinator.
Legal Authority
Legal authority for the implementation of the pre-treatment program is contained in the
Municipal Code of the City of Oshkosh, Sections 24-6.0 through 24-6.8 as summarized below:
24-6.0 Definitions — this Section provides a glossary of terms.
24-6.1 Regulation of the Wastewater System — this Section provides regulation of
usage of the sewer system, including prohibitions on discharge of harmful
materials.
24-6.2 Slug Discharge Plan — this Section lays out the criteria for industrial slug
control plans and the definition of slug discharges.
24-6.3 Control of Industrial Wastewater Discharges — this Section provides for the
regulation and implementation of the Industrial Pre -Treatment Program.
24-6.4 Industrial Wastewater Discharge Program Charges — this Section
establishes the Industrial Pre -Treatment Program charge system.
24-6.5 Wastewater Service Charges — this Section provides the basis for user
charges.
24-6.6 Right of Entry, Safety, and Identification — this Section authorizes
representatives of the City to enter private property for purposes of
inspection, observation, and testing in relation to the program, and assigns
responsibility of safety and identification.
6
24-6.7 Administrative Enforcement Remedies — this Section contains provisions
pertaining to notices of violation, accidental discharges, and continued
violations; liability, penalties, and injunctive relief; publications of
violations, appeals and records retention; and hazardous wastes and
bypass.
24-6.8 Validity — this Section contains clauses dealing with repeal of conflicting
ordinances, invalidation, and amendments.
24-6.9 Annual Audit — this Section provides for an annual audit of the equity and
validity of the user system and pre-treatment program charges.
24-7.0 Mercury Minimization Program
Program Operation
The Pre -Treatment Coordinator will be responsible for administration of the program,
and for updating the technical analysis information and ordinance limits under the
direction of the Director of Public Works. This includes the responsibility to review
technical submittals, plans, and specifications for industrial pre-treatment facilities. In
those instances where highly -specialized process calculations and/or designs are
submitted, the Director of Public Works may retain the services of an outside consultant.
All costs associated with such review shall be billed to the affected industry.
The Pre -Treatment Coordinator will be responsible for the administration of the sampling
and monitoring program, analysis of monitoring data, obtaining and updating industrial
baseline information, issuance of citations, enforcement inspections, user charge
determinations, and review of accidental spill plans. Spill plans will be reviewed on a
case-by-case basis, depending on site conditions.
The Pre -Treatment Coordinator will establish a secure file for each industry. Chain -of -
custody procedures will be enforced by the Program Coordinator. Copies of all reports
and forms will be kept on file. An annual report on the program will be prepared by the
Pre -Treatment Coordinator.
The Pre -Treatment Coordinator will be responsible for providing industrial users with
new, or changed, pre-treatment standards and requirements (Federal, State, or Local, as
applicable).
When new standards are promulgated, or changes made to the existing Pre -Treatment
Standards, the City will notify industrial users in writing.
When there are planned changes in production or processes which may alter the
industry's wastewater characteristics, the industry shall notify the Pre -Treatment
Coordinator in writing prior to implementation.
The Pre -Treatment Coordinator will be responsible for receiving, reviewing, and
analyzing all compliance schedules obtained from industrial users. Within 180 days after
the promulgation of a pre-treatment standard, existing industrial users subject to such
pretreatment standards and currently discharging or scheduled to discharge into the
City's system will be required to submit to the Pre -Treatment Coordinator a revised
discharge permit application. The City shall issue a new permit with a compliance
schedule, if required.
Within 90 days following the date for final compliance with applicable pre-treatment
standards or, in the case of a new source, following commencement of the introduction
of wastewater into the City's system, any industrial user subject to pre-treatment
standards and requirements shall resubmit to the Program Coordinator Part "C" of the
Baseline Report, indicating the nature and concentration of all pollutants in the discharge.
This report shall address each regulated process subject to pre-treatment standards and
requirements which contributes to the discharge. The report shall reflect the results of
the City's monitoring program and state whether the applicable pre-treatment standards
and requirements are being met on a consistent basis and, if not, what additional
operations and maintenance provisions, and/or pre-treatment is necessary to bring the
industrial user into compliance with the applicable pre-treatment standards or
requirements. This statement shall be signed by an authorized representative of the
industrial user.
Enforcement of the provisions of the Industrial Pre -Treatment Program is a key element
of a successful pre-treatment program. Monitoring reports, test results, surveillance
reports, and all other information obtained through the monitoring program will be used
to determine compliance. The tracking of violators will be the responsibility of the Pre-
treatment Coordinator. All violators will be notified in writing of non-compliance.
Follow-up surveillance and monitoring may be required for all violations. In situations
where violations are accidental, such as a broken pipe within the process or other
equipment, or other apparatus being out of service temporarily, the Pre -Treatment
Coordinator may determine if follow-up surveillance or monitoring is unnecessary.
However, any industry found to be responsible for accidental discharges causing damage
S
to or having a deleterious effect upon the City's treatment works, processes, equipment,
or receiving waters shall, in addition to any forfeiture, be required to pay the amount to
cover damages. Both values will be determined by the Pre -Treatment Coordinator, and
approved by the Director of Public Works.
The written notice of non-compliance shall state the nature of the violation and shall
provide a reasonable time for the satisfactory correction thereof. The offender shall,
within the period of time stated in such notice, permanently cease all violations. Any
industry continuing any violation beyond the time limit provided in the written notice of
non-compliance shall, upon conviction, forfeit no more than $5,000, together with the cost
of prosecution. Each day in which any violation is continued beyond the aforesaid notice
time limit shall be deemed a separate offense.
Each Significant Industrial User, or Significant User, shall apply for and obtain a
Wastewater Discharge Permit from the City. The permit will be for a five (5) year period
with renewal application required prior to expiration. Following the issuance of a
Wastewater Discharge Permit, the Director of Public Works will have the power to revoke
any permit for non-compliance. The City may, at its option, impose a fee for
reinstatement of revoked discharge permits.
All records, reports, correspondence, memoranda, documents, and record books
pertaining to industries within the program shall be retained and preserved for no less
than three (3) years. All records, documents, or information pertaining to enforcement
activities or litigation shall be retained until all enforcement activities have been
concluded and all litigation matters have been resolved.
An updated list of the City's Industrial Users, including their names and addresses, will
be included with the annual report to the WDNR. A brief explanation of each deletion
will be included. This list shall identify which industrial users are subject to categorical
pre-treatment standards and specify which standards are applicable to each industrial
user. The list shall indicate which industrial users are subject to local standards that are
more stringent than the categorical pre-treatment standards, and the industrial users that
are subject only to local requirements.
The annual report will also include:
(A) A summary of the status of industrial user compliance over the reporting
period;
9
(B) A summary of compliance and enforcement activities (including inspections)
conducted by the POTW during the reporting period; and
(C) Any other relevant information requested by the Approval Authority.
The annual report shall contain the results of sampling and analysis of the industrial
discharge, including the flow and the nature and concentration, or production and mass
where requested by the Control Authority, of pollutants contained therein which are
limited by the applicable Pre-treatment Standards.
The Program Coordinator will develop annual reports on violators. These procedures
will provide for an annual public notification in the City's official publication daily
newspaper of industrial users which, during the past twelve (12) months, were
significantly in non-compliance. For the purpose of this publication, "Significantly in
Non -Compliance" will refer to violations which are:
(A) Chronic violations of wastewater discharge limits, defined as those in which
sixty-six percent (66%) or more of all of the measurements taken during a six
(6) month period exceed (by any magnitude) the daily maximum limit or the
average limit for the same pollutant parameter;
(B) Technical Review Criteria (TRC) violations, defined as those in which thirty-
three percent (33%) or more of all of the measurements for each pollutant
parameter taken during a six (6) month period equal or exceed the product
of the daily maximum limit or the average limit multiplied by the applicable
TRC (TRC = 1.4 for SOD, TSS, fats, oils, and grease; and 1.2 for all other
pollutants except pH);
(C) Any other violation of a pre-treatment effluent limit (daily maximum or
longer term average) that 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 that has caused imminent endangerment to
human health or welfare, or to the environment, or has resulted in the
POTW's exercise of its emergency authority under Paragraph (f) (1) (vi) (B)
of this Section to halt or prevent such a discharge;
10
(E) Failure to meet, within 90 days after the schedule date, a compliance schedule
milestone contained in a local control mechanism 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, periodic self-
monitoring reports, and reports on compliance with compliance schedules;
(G) Failure to accurately report on non-compliance;
(H) Any other violation or group of violations which the Control Authority
determines will adversely affect the operation or implementation of the local
pre-treatment program.
Definitions
Act Federal Water Pollution Control Act, also known as the Clean
Water Act of 1977, as amended.
ApprovalAuthority The Wisconsin Department of Natural Resources,
Industrial Pre -Treatment Control.
Average Monthly The highest allowable average of "daily discharge" over a
Discharge calendar month, calculated as the sum of all daily discharges
Limitation measured during a calendar month divided by the number of
daily discharges measured during that month.
Average Weekly The highest allowable average of "daily discharges" over a
Discharge Limitation calendar week, calculated as the sum of all daily discharges
measured during a calendar week divided by the number of
daily discharges measured during that week.
Base/Neutral The group of organic priority pollutants associated with the
methylene chloride extract of a composite wastewater
sample. There are 46 Base/Neutral compounds.
11
Biochemical Oxy&en The quantity of dissolved oxygen in milligrams per liter
Demand (BOD) required during stabilization of the decomposable organic matter
by aerobic biochemical action under standard laboratory
procedures for five (5) days at 20 degrees Centigrade. The
laboratory determinations shall be made in accordance with
procedures set forth in "Standard Methods".
EPA The U.S. Environmental Protection Agency, or
w h e r e appropriate the term may also be used as a
designation for the administrator or other duly -authorized
official of said agency.
Fecal Coliform Any of a number of organisms common to the intestinal
tract of man and animals, whose presence in sanitary sewage
is indicator of pollution.
Indirect Discharge Introduction of pollutants into a POTW from any non-domestic
source regulated under Section 307(b) or (c) of the Act.
Industrial User A source of indirect discharge.
Influent The water, together with any waste that may be present, flowing
into a drain, sewer, receptacle, or outlet.
Interference The inhibition or disruption of the POTW treatment processes
or operations which contributes to a violation of any
requirement of the City's WPDES Permit. The term includes
prevention of sewage sludge use or disposal by the POTW in
accordance with Section 405 of the Act, (33 U.S.C. 1345) or
any criteria, guidelines, or regulations developed
pursuant to the Solid Waste Disposal Act (SWDA), the
Clean Air Act, the Toxic Substances Control Act, or more -
stringent State criteria (including those contained in any State
sludge management plan prepared pursuant to Title IV of
SWDA) applicable to the method of disposal or use employed
by the POTW.
12
National Pre- Any EPA regulation containing pollutant discharge
Treatment Standard or limits, promulgated in accordance with the Act.
"Pre-Ttreatment Includes categorical and prohibited standards.
Standard"
New Source New source means any building, structure, facility, or installation
from which there is or may be a discharge of pollutants regulated
under the Program, created after the publication of proposed
Pre -Treatment Standards under Section 307(c) of the
Act, provided that (i) the construction is a site at
which no other source is located; or (ii) the process or
production equipment that causes the discharge of pollutants at
an existing source is totally replaced; or (iii) the
production of wastewater -generating processes are
substantially independent of an existing source at the same
site.
Pass Through Discharge, which alone or in conjunction with a discharge or
discharges from other sources, exits the POTW and is a cause
of a violation of any requirement of the POTW's WPDES
permit (including an increase in the magnitude or duration of
a violation).
pH The logarithm (to the base 10) of the reciprocal of the
hydrogen ion concentration of a solution expressed in gram
atoms per liter of solution.
Pickle Liquor Waste product recovered from acid (sulfuric or
hydrochloric) cleaning of steel. The high iron
concentration in the pickle liquor is used to remove
phosphorus in wastewater treatment plants.
Pollution An alteration of the quality of the waters of the State by waste
to a degree which unreasonably affects such waters for
beneficial uses or facilities which serve such beneficial uses. The
man-made or man -induced alteration of the chemical,
physical, biological, and radiological integrity of water.
13
POTW Publicly -Owned Treatment Works — A treatment works, as
defined in the Act, which is owned by a State or
municipality. POTW shall mean the City of Oshkosh's POTW.
POTW Control The Control Authority, as defined by the Municipal Code of the
Agency or "Control City of Oshkosh, having jurisdiction over indirect discharges to
Authority" and discharges from a POTW. The Control Authority is the
Oshkosh City Manager or duly -authorized deputy, agent, or
representative.
POTW Pre -Treatment A program administered by a POTW control agency and
Program or approved by the Regional EPA Administrator or State
"Program" Director.
POTW System Any sewage treatment works and the sewers and
conveyance appurtenances discharging thereto, owned and
operated by the City or Oshkosh.
Pre -Treatment The reduction of the amount of pollutants, the elimination of
pollutants, or the alteration of the nature of pollutant
properties in wastewater prior to or in lieu of discharge in or
otherwise introducing such pollutants into a POTW.
Significant Any industrial user of the City's wastewater disposal system
Industrial User who:
SIU 1. Discharges an average of 25,000 gallons per
day or more of process wastewater to the
POTW (excluding sanitary, non -contact
cooling, and boiler blowdown wastewater);
2. Contributes a process waste stream which
makes up 5 percent or more of the
average dry weather hydraulic or organic
capacity of the POTW treatment plant;
3. Has reasonable potential for adversely
affecting the POTW's operation or for
violating any pre-treatment standard or
requirement (in accordance with 40 CFR
403.8(f)(6));
14
4. Has a significant impact, either singly or in
combination with other contributing
industries, on the wastewater treatment
system, the quality of sludge, the system's
effluent quality, or air emission generated
by the system;
5. All Industrial Users subject to Categorical
Pre -Treatment Standards under 40 CFR
403.6 and 40 CFR Chapter 1, Subchapter N,
or discharges toxic pollutants in amounts
potentially or actually exceeding limits set
forth in Chapter 24, Municipal Code of the City
of Oshkosh;
6. Any other Industrial User designated as a
Significant Industrial User by the Control
Authority.
Upon a finding that an industrial user meeting the
criteria above has no reasonable potential for adversely affecting
the POTW's operation or for violating any pre-treatment
standard or requirement, the Control Authority may at
any time, or its own initiative or response to a petition
in accordance with 40 CFR 403.8(f)(6), determine that an
Industrial User is not a Significant Industrial User.
Sludge Any solid, semi-solid or liquid waste generated from a
municipal, commercial, or industrial wastewater treatment plant,
water supply treatment plant, or air pollution control facility
or any other waste having similar characteristics and effects
as defined in standards issued under Sections 402 or 405 of
the Act and in the applicable requirements under Sections
3001, 3004, and 4004 of the Solid Waste Disposal Act PL 94-
580.
15
Slug Loading Any discharge of water or wastewater which, in concentration
of any given constituent or in quantity of flow, exceeds for any
period of duration longer than 15 minutes more than five (5)
times the average 24-hour concentration or flows during normal
operation and shall adversely affect the system and/or
performance of the wastewater treatment works.
The examination and analytical procedures set forth in 40
Standard Methods C.F.R. Part 136.
Suspended Solids Solids which either float on the surface of or are in suspension
in water, sewage, or other liquid and which are removable by
laboratory filtration. Their concentration shall be expressed in
milligrams per liter. Quantitative determination shall be made
in accordance with procedures set forth in "Standard
Methods".
Total Solids The sum of suspended and dissolved solids.
Toxic Pollutant Defined as those substances referred to in Section 307(a) of
the Act as well as any other known potential substances capable
of producing toxic effects.
User
Wastewater
Constituents and
Characteristics
WPDES
Any person that discharges, causes, or permits the
discharge of wastewater into the sewerage system.
The individual chemical, physical, bacteriological, and
radiological parameters, including volume, flow rate, and
such other parameters that serve to define, classify, or measure
the contents, quality, quantity, and strength of wastewater.
Wisconsin Pollutant Discharge Elimination System
16
Chapter 2. Industrial Monitoring Program
INTRODUCTION
Baseline data about individual industries has been developed, and a basis has been
established for setting specific industrial -discharge limits for prohibited substances in
the City's sewer use ordinance. However, it has also been recognized that some of the
baseline data and some of the WWTP data is incomplete, and is subject to change.
In addition, as state-of-the-art advances are made, industrial processes can change, as
can State and Federal regulations. Therefore, in recognition of the dynamic nature of
this program, and to guard the general public from the potential future discharge of toxic
and environmentally -degrading substances, an industrial wastewater discharge
monitoring program has been established. This program is mandated by Federal and
State law, and has been developed under the guidance of the Wisconsin
Department of Natural Resources.
MONITORING METHODS AND PROCEDURES
The Industrial Monitoring Program is an essential part of the Industrial Wastewater
Discharge Program because it provides the City of Oshkosh with a continuing source
of information on the pollutants and other wastewater constituents introduced in the
sewerage system. This information can then be applied to various specific areas of
concern to the City. These specific areas include compliance with sewer use
ordinance requirements, ascertaining user charge fees, and completion of reports
required by the EPA and/or the WDNR. Each Significant Industrial User, or Significant
User, shall apply for and obtain a Wastewater Discharge Permit from the City. The
permit will be for a five (5) year period with renewal application required prior
to expiration. Following the issuance of a Wastewater Discharge Permit, the
Director of Public Works will have the power to revoke any permit for non-compliance.
The City may, at its option, impose a fee for reinstatement of revoked discharge permits.
SIGNIFICANT INDUSTRIAL USER NOTIFICATION
Within 30 days of listing an industry as significant, the City will notify the Industrial User
of its status and all requirements applicable to it as a result of such status.
17
SAMPLING PROCEDURES
To provide accurate and consistent data, the sampling procedures to be utilized in this
program will follow EPA recommended techniques. Proper sample collection, handling,
and preservation is essential to obtain representative data.
Field personnel will collect samples that are most representative of the waste or process
stream. Equally important to proper sample collection is the selection and installation of
proper sampling equipment. Sampling personnel will be trained to install all
equipment according to the manufacturer's direction and to choose the right
equipment for physical or hydraulic conditions. The City may hire an independent
certified laboratory to perform all necessary sampling and testing as required to fulfill
the needs of the program. The qualified lab will be solicited pursuant to the City's
Purchasing Ordinance. The length of the contract term shall be determined by the
Director of Public Works in conjunction with the Finance Department to minimize costs.
Each industry to be sampled will receive a notification in advance providing all of the
applicable information for that industry's annual monitoring program. In addition,
industries may receive notification of additional sampling and inspections as
deemed appropriate by the City.
Each industry sampled will be visited by an individual experienced in sampling
techniques, hydraulics, and familiar with plant processes. A representative
sampling location will be determined and the parameters to be measured and procedures
to be followed for each industry will be selected. Because of the wide variety of conditions
to be encountered at the various industries, each sampling or monitoring activity will
require good judgement and proper equipment. A well-equipped vehicle will be
used for field activities. Proper safety equipment will be used under all
circumstances. All necessary tools and equipment shall be supplied by the field
technician. All sampling will be conducted by trained personnel from a single,
City -selected, State -certified laboratory.
SIGNIFICANT INDUSTRIAL USER INSPECTIONS AND SAMPLING
In addition to sampling and analysis of industrial waste, the City will evaluate, at least
every two (2) years, whether each Significant Industrial User needs a plan to control Slug
Discharges. A Slug Discharge is any discharge of a non -routine, episodic nature,
including, but not limited to, an accidental spill or a non -customary batch discharge. If
the City decides that a slug control plan is needed, the plan shall contain the following
elements:
18
(A) Description of discharge practices, including non -routine batch discharges;
(B) Description of stored chemicals;
(C) Procedures for immediately notifying the POTW of slug discharges,
including any discharge that would violate a prohibition under 40 CFR
403.5(b), with procedures for follow-up written notifications within five (5)
days;
(D) If necessary, procedures to prevent adverse impact from accidental spills,
including inspection and maintenance of storage areas; handling and
transfer of materials; loading and unloading operations; control of plant site
run-off; worker training; building of containment structures of
equipment; measures for containing toxic organic pollutants (including
solvents); and/or measures and equipment for emergency response.
CHAIN -OF -CUSTODY
Specific procedures must be followed after the collection of each field sample. Once the
sample is obtained by sampling personnel, it is essential the Chain -of -Custody be
properly documented. Written documentation of collection, possession transfer, analysis,
storage, destruction, data transfer, and filing is essential. This written documentation
will be accomplished through the use of a Chain -of -Custody form. No laboratory fees
will be paid by the City for data transmitted from the laboratory to the City without this
documentation attached. No results on file will be considered valid without this
documentation attached. Periodic audits of the City's selected laboratory will be
conducted to ensure this document accompanies sample and analysis results at all times
in the laboratory. Failure to follow these procedures will be grounds for dismissal of
the selected laboratory for that year. In addition, the selected laboratory will be
required to submit a quality control program, which will provide measures which
ensure the integrity and security of samples and sample analysis data.
19
All Chain -of -Custody and laboratory analysis data will be kept in lockable files in the
Program Coordinator's office. Access to files will be controlled by the Coordinator
and all files will be signed in and out on the Chain -of -Custody document for that file.
Access by the public to all program documents will be administered in accordance with
State Statutes. File records will be retained a minimum of 3 years and shall be
available for inspection and copying by the Director and the Regional
Administrator. This period of retention shall be extended during the course of any
unresolved litigation regarding the POTW Pre -Treatment Program or when requested
by the Director or the Regional Administrator.
ANALYTICAL PROCEDURES
Analytical procedures will be in accordance with those described in Chapter NR 219
"Analytical Test Methods and Procedures" Wisconsin Administrative Code; the most -
recent edition of "Standard Methods for the Examination of Water and Wastewater,"
published by APHA, AWWA, and WPCF; and 40 CFR 136.
SAFETY PROCEDURES
City personnel must be familiar with the safety procedures outlined in the City's
Employee Safety Handbook. In addition, the laboratory sampling crew should,
at a minimum, carry with them the following: hard hat, gas detector, rubber gloves,
boots, safety goggles, first aid kit, and other clothing required for adequate protection
for specific monitoring activities.
RIGHT -OF -ENTRY
A right -of -entry procedure has been established through Section 24-6.6(A) of the
Municipal Code of the City of Oshkosh, which states in part: "The Director of Public Works,
Superintendent of Wastewater Treatment Plant, Plumbing Supervisor, or other duly -
authorized representatives or employees of the City, bearing proper
credentials and identification, shall be permitted to enter all properties for the purpose
of inspection, observation, testing, all in accordance with the provisions of this
ordinance and Section 196.171 of the Wisconsin State Statutes".
ENFORCEMENT STANDARDS AND REQUIREMENTS
The City shall have the authority (after informal notice to the discharger) to immediately
and effectively halt or prevent any discharge of pollutants to the POTW which reasonably
appears to present an imminent endangerment to the health or welfare of persons.
20
The City shall also have authority (which shall include notice to the affected
industrial users and an opportunity to respond) to halt or prevent any discharge to
the POTW which presents or may present an endangerment to the
environment or which threatens to interfere with the operation of the POTW.
MONITORING PROGRAM
This industrial wastewater discharge monitoring program has been designed to
obtain industrial discharge data from Oshkosh industries for the following
purposes:
(A) Sewer User Charges — The City of Oshkosh Sewer Use Ordinance
provides for the billing of surcharges for volumes of industrial waste
containing organic loadings of SOD, SS, Ammonia, and/or Phosphorus in
excess of domestic waste loading, as defined by that Ordinance. Those
industries subject to monitoring for these surcharges have been included
in this program.
(B) Prohibited Substances — The City of Oshkosh Sewer Use Ordinance Section
24-6.1(C) contains general discharge prohibitions for pollutants which will
interfere with the operation or performance of the City's Wastewater System.
The proposed limits are maximums not to be exceeded at any time and
apply to the total discharge from a user exclusive of sanitary wastewater,
uncontaminated cooling water, and dilution water. In general, the City will only
monitor those industries for these substances when it has reason to believe that
violations of this provision of the ordinance may be occurring. Those
industries currently subject to prohibited substances monitoring have
been included in this program.
(C) NR 101 Monitoring — The State of Wisconsin has established a separate
industrial monitoring program of selected industries. Those industries are
required to monitor and report certain discharge parameters in January of
each year. This monitoring requirement has been incorporated into the City's
Industrial Monitoring schedule to prevent duplication of effort. Reports
will be furnished to affected industries in sufficient time for them to
provide the data to the State.
21
EPA POINT SOURCE CATEGORICAL PRE-TREATMENT STANDARDS
The EPA requires regulation of various classifications of industrial processes which
must be monitored, and which may not discharge effluent containing
pollutant concentrations exceeding certain limits established in these standards.
A monitoring report for this program is required within 180 days of promulgation of
any new regulation, and in June and December, thereafter. The actual monitoring will
take place quarterly. Additionally, a compliance and monitoring report is required
within 90 days following the date for final compliance with the applicable pre-
treatment standard, or within 90 days following the commencement of the
introduction of wastewater into the system from a new source already subject to a
standard. These monitoring requirements have been incorporated into this Industrial
Monitoring Program.
INTERPRETATION OF MONITORING PROGRAM RESULTS
The Pre -Treatment Coordinator shall review laboratory reports of analysis of
wastewater against permit limitations for each industry. Reports of significant
non-compliance shall be determined within 5 working days (excluding holidays,
weekends, and vacations) of receipt of laboratory results and notice of non-
compliance
on-
compliance forwarded to industry in writing.
MONITORING PROGRAM UPDATING PROCEDURE
In accordance with State and Federal regulations, at the beginning of each year, the Pre-
treatment Coordinator must update the Industrial Monitoring Program schedule for each
industrial process wastewater discharger. To accomplish this, the following steps
should be followed, upon receipt of the December laboratory data:
1. Water use records for each industrial discharger shall be compared to
values given in the baseline reports. If significant changes have occurred,
a facility contact should be made.
2. If a facility contact is made and a significant process change or addition h a s
been made, or if an industry reports significant process changes, the
following additional steps are required:
a. If a process has changed, the industry must resubmit Part C of its baseline
report for that process.
22
b. If a new process has been added which produces a new discharge to
the sewer system, the industry must submit a new application for a
discharge permit, including a new baseline report.
3. Wastewater treatment plant monitoring data shall be reviewed and analyzed.
If major changes in pollutant loads or violations, are found for
specific industries, consideration must be given to increasing or
decreasing the frequency of monitoring for that industry.
4. Monitoring data recorded for each individual industry should be reviewed
for significant changes and/or violations. If either has occurred, a facility
contact shall be made to find out why. Steps 2 (a) and (b) should be
followed if process changes have occurred. In addition, if violations
have occurred, a formal notice of violation should be issued, a compliance
schedule prepared, and a new permit issued containing that
schedule. Based on the information obtained from this step, adjustments
should be made to the monitoring schedule for the specific industries affected.
5. Monitoring data recorded for each industry should also be reviewed for
the following reasons:
a. If the parameters are being monitored for purposes of satisfying only
City of Oshkosh user charge and prohibited substances
requirements, it should be determined if the frequency of monitoring
should be increased or decreased.
b. A determination should be made whether the State NR 101
reporting requirements for that industry changed since the last review. To
determine this, the Pre -Treatment Coordinator must contact the
WDNR Industrial Pre -Treatment office in Madison, Wisconsin.
c. A determination should be made whether new Federal regulations
have been issued for point source categorical pre-treatment
standards. The Program Administrator must contact the
WDNR Industrial Pre -Treatment office in Madison, Wisconsin,
annually to update the file of regulations.
6. Upon completion of each industry's annual monitoring program, the City-wide
annual monitoring program summary should be prepared.
23
7. Upon completion of the City-wide annual monitoring program, the proposed
monitoring program should be reviewed with the WDNR.
24
Chapter 3. Financial Program
INTRODUCTION
A financial program for the Industrial Wastewater Discharge Program has been
developed in accordance with requirements contained in Federal and State
regulations. The objectives of this program are as follows:
1. To minimize the cost to all industries included in this program.
2. To ensure that all costs associated with this program are borne by the
affected industries.
Program costs are composed of two elements. These elements and the methods used to
allocate their associated costs are discussed below.
INDIVIDUAL INDUSTRY COSTS
All program sampling and analysis will be performed by a single laboratory. Upon
completion of the annual monitoring program forms described in Chapter 2, a specification
will be prepared, and qualified firms will be solicited pursuant to the City's Purchasing
Ordinance. Itemized responses will be required from bidders which will permit
development of each industry's estimated annual monitoring cost. This estimated
cost will be entered on each industry's individual monitoring schedule, which contains a
column for estimated monitoring costs.
Each industry will be billed biannually for the actual costs associated with that
industry's monitoring program for the fiscal year.
ADMINISTRATIVE COSTS
Each year, an annual budget will be prepared which estimates the hours, materials, and
wastewater treatment plant monitoring costs which will be required by the City to
administer the next year's program. This cost will then be allocated to each industry
in proportion to that industry's estimated individual program cost. This anticipated
cost will be included as a line item on the April invoice to that industry. Based
on an audit of actual individual industry and administrative costs for the previous year,
deductions or additions will then be made on the next year's first invoice for the previous
year's actual administrative costs.
25
In addition to these program -wide estimated annual costs, legal fees, fines, and other
unanticipated costs may occur. Wherever feasible, these costs will be assigned
directly to the industry causing these increased costs. Billing for these costs will
normally be done on the first invoice, except for court -mandated fines and legal fees.
These will be invoiced separately, and will be credited to the City's general revenue
fund, as appropriate. Such income will not be used to reduce the program's administrative
costs.
26
Chapter 4. References, Regulations, Standards, and Ordinances
1. Federal Environmental Protection Agency Pre -Treatment Standards.
2. State of Wisconsin Administrative Code Sections NR 100 through NR 199, relating to
General Environmental Protections.
3. State of Wisconsin Administrative Code Sections MR 200 through NR 299, relating
to the Wisconsin Pollutant Discharge Elimination System.
4. Chapter 24, Sewer Use Ordinance, of the Municipal Code of the City of Oshkosh.
27
Chapter 5. Enforcement Response Plan
INTRODUCTION
The City of Oshkosh regulates discharges to the sewerage system under a pre-treatment
program approved by the Wisconsin Department of Natural Resources. The City has the
primary responsibility to enforce all applicable pre-treatment requirements and standards. In
accordance with Federal regulations, this Enforcement Response Plan has been developed to
provide guidance for possible enforcement responses to be sought for violations of Federal,
State, or local pre-treatment standards and requirements.
In determining the appropriate enforcement response to be taken by the City, several factors
will be considered. However, since pre-treatment enforcement is a matter of strict
liability, the knowledge or intent of the user, under most circumstances, will not be taken
into consideration, except in the case of criminal enforcement of intentional, willful, or
deliberate violations.
Since it is appropriate for the enforcement response to be tailored to the violation, the City will
take the following factors into consideration when it decides within its discretion to proceed
with a particular enforcement response:
• Magnitude of the violation
• Duration of the violation
• Effect of the violation on the receiving water
• Effect of the violation on the POTW
• Compliance history of the Industrial User
• Good faith of the Industrial User
The enforcement plan is a guidance document. The City may, and will, take such enforcement
actions as are appropriate, whether or not the actions are in accordance with the Plan.
28
DEFINITION OF ENFORCEMENT RESPONSES
(A) Administrative Order (AO) — If after a Notice of Violation (NOV) has been issued,
and non-compliance continues beyond time allowed to correct, or the non-
compliance requires a more forceful response from the City due to imminent danger
to the POTW or its personnel, the public, or the environment, the Pre -Treatment
Control Coordinator may issue an Administrative Order requiring corrective
action.
(B) Civil Action — When an industry has violated any portion of a discharge permit or
the sewer user ordinance, or has failed to comply with an order to correct such a
violation, the Control Authority or Director of Public Works may issue a citation for
such violation or involve court action to halt any such violation.
(C) Criminal Investigation — Any time the City feels an industry is non-compliant
for reasons that would make such non-compliance a criminal offence, the City
Manager or Director of Public Works may institute an investigation of
all circumstances and records which may be evidence in a criminal prosecution
for such non-compliance. Such investigation could involve review of industry
records and/or monitoring of the industry's wastewater discharge at any frequency
necessary to determine the nature and extent of a violation.
(D) Notice of Violation (NOV) — At any time the City is aware an industry is in non-
compliance with the discharge limits or reporting requirements of their
discharge permit or requirements of the City's Sewer Use
Ordinance, the Pre -Treatment Control Coordinator will issue a written notice
to the industry.
(E) Show Cause — If an Administrative Order has not been complied with, the Director
of Public Works may issue a Show Cause Order allowing an industry in
violation a specific time to respond before the City issues a citation for failure to
correct, or applies penalties under Chapter 24-6.7 of the Municipal Code
of the City of Oshkosh.
(F) Terminate Service —When an industry's discharge violation has not been corrected,
or the discharge poses an imminent danger to the POTW or its personnel, the public,
or the environment, the City Manager or Director of Public Works may have the
29
industry's sewer service uncovered and plugged. Cost for termination will be at
the industry's expense. A terminated service may not be reconnected until
corrections are complete and all costs associated with the termination have been
recovered by the City.
(G) Slug Load — Any non -routine, episodic discharge, such as a discharge
resulting from a spill or non -customary batch discharge.
INVESTIGATION OF NON-COMPLIANCE
Industries in the Pretreatment Program will be monitored as frequently as required
under Federal, State, or local regulations. Minimum monitoring will include quarterly wastewater
analysis, and annual onsite inspection. When an industry's wastewater sample is found to be in
non-compliance with a discharge limit, the Control Authority may schedule additional
sampling events of that waste discharge until compliance with limits is demonstrated. At
the Control Authority's discretion, an onsite conference and/or inspection may be
performed after any event the Control Authority determines is significant non-
compliance. Significant Non-Ccompliance will be determined from data supplied from
analysis of industry's wastewater or notice from industry concerning spills, batch and
hazardous waste discharges, upsets, by-pass, or changed production levels.
ENFORCEMENT RESPONSE GUIDE
The following courses of action contained in the Enforcement Response Guide may serve as a
general guideline; however, the City reserves the right to take any action as it deems
appropriate based on the individual circumstances of each situation.
S = Director of Public Works PC = Pre -Treatment Coordinator
CA = City Manager
30
UNAUTHORIZED DISCHARGES (No Permits)
NON-COMPLIANCE
1. Un -Permitted
Discharge
2. Non -Permitted
Discharge (failure to
renew)
NATURE OF THE
T ]T T A TT A T
IU unaware of
requirement; no harm
to POTW or
environment
IU unaware of
requirement; harm to
POTW
Failure to apply
continues after notice
by POTW
IU has not submitted
application within 10
days of due date
31
ENFORCEMENT PERSONNEL
TT rnTT�r Tnrn
- Phone call; NOV with PC
application form
- AO PC
- Civil Action S, CA
- Civil Action
- Criminal
Investigation
- Service Termination
- Phone call; NOV
S, CA
S, CA
S, CA
PC
DISCHARGE LIMIT VIOLATION
NON-COMPLIANCE NATURE OF THE
1. Exceedance of local
or Federal Standard
(permit limit)
VIOLATION
ENFORCEMENT PERSONNEL
RESPONSES
Isolated, not significant - Phone call; NOV PC
Isolated, significant; no - AO to develop spill PC
harm to POTW or prevention plan
environment
Isolated; harm to - Show Cause Order S
POTW or environment - Civil Action S, CA
Recurring; no harm to - AO PC
POTW or environment
Recurring, significant;
harm to POTW or
environment
32
- AO PC
- Show Cause Order S
- Civil Action S, CA
- Terminate service S, CA
MONITORING AND REPORTING VIOLATIONS
NON-COMPLIANCE NATURE OF THE ENFORCEMENT PERSONNEL
VIOLATION
RESPONSES
1. Reporting violation Report is improperly -
Phone call or NOV
PC
signed or certified
Report is improperly -
AO
PC
signed or certified after -
Show Cause Order
S
notice by POTW
Isolated, not significant -
Phone call; NOV
PC
(e.g., 5 days late)
Significant (e.g., report -
AO to submit
PC
45 days or more late) -
Civil Action
S, CA
Reports are always late -
AO
PC
or no reports at all -
Show Cause Order
S
-
Civil Action
S, CA
Failure to report spill -
NOV
PC
or changed discharge
(no harm)
Failure to report spill -
AO
PC
or changed discharge -
Civil Action
S,CA
(results in harm)
33
MONITORING AND REPORTING VIOLATIONS (Continued)
NON-COMPLIANCE
NATURE OF THE
VIOLATION
Falsification
Repeated failure to
report spills
ENFORCEMENT PERSONNEL
RESPONSES
- Civil Action S, CA
- Criminal S, CA
investigation
- Service termination S, CA
- Show Cause Order S, CA
- Civil Action S, CA
- Service termination S, CA
Falsification - Civil Action S, CA
- Criminal S, CA
investigation
- Service termination S, CA
2. Failure to monitor Failure to monitor all - NOV or AO PC
correctly pollutants as required
by permit
3. Improper sampling Evidence of intent
34
- Criminal S, CA
investigation
- Service termination S, CA
MONITORING AND REPORTING VIOLATIONS (Continued)
NON-COMPLIANCE NATURE OF THE ENFORCEMENT PERSONNEL
VIOLATION RESPONSES
4. Failure to install Delay of less than 30 - NOV PC
monitoring equipment days
Delay of 30 days or - AO to install PC
more
Recurring, violation - Civil action S, CA
of AO - Criminal S, CA
investigation
- Service termination S, CA
5. Compliance schedules Missed milestone by - NOV or AO PC
less than 30 days or
will not affect final
milestone
Missed milestone by - AO PC
more than 30 days or
will affect final
milestone (good
cause for delay)
Missed milestone by - Show Cause Order S
more than 30 days, or - Civil Action S, CA
will affect final - Service termination S, CA
milestone (no good
cause for delay)
35
MONITORING AND REPORTING VIOLATIONS (Continued)
NON-COMPLIANCE NATURE OF THE
VIOLATION
Recurring violation
or violation of
schedule in AO
36
ENFORCEMENT PERSONNEL
RESPONSES
- Civil Action S, CA
- Criminal S, CA
investigation
- Service S, CA
termination
NON-COMPLIANCE
1. Waste streams are
diluted in lieu of
treatment
OTHER PERMIT VIOLATIONS
NATURE OF THE
VIOLATION
Initial violation
Recurring
2. Failure to mitigate non- Does not result in
compliance or halt harm
production
3. Failure to properly
operate and maintain
pre-treatment facility
Does result in harm
Does not result in
harm
ENFORCEMENT
RESPONSES
- AO
PERSONNEL
PC
- Show Cause Order S
- Service termination S, CA
- NOV PC
- AO PC
- Civil Action S, CA
- NOV PC
Does result in harm - AO PC
- Civil Action S, CA
37
VIOLATIONS DETECTED DURING SITE VISITS
NON-COMPLIANCE NATURE OF THE ENFORCEMENT PERSONNEL
VIOLATION RESPONSES
1. Entry denial Entry denied or - Obtain warrant and PC, CA
consent withdrawn. return to IU
Copies of records
denied
2. Illegal discharge No harm to POTW or - AO PC
environment - Civil Action S, CA
Discharge causes - Civil Action S, CA
harm or evidence of - Criminal S, CA
intent/negligence investigation
Recurring, violation - Service termination S, CA
of AO
3. Improper sampling Unintentional - NOV PC
sampling and
incorrect location
Unintentionally using - NOV PC
incorrect sample type
Unintentionally using - NOV PC
incorrect sample
collection techniques
38
VIOLATIONS DETECTED DURING SITE VISITS (Continued)
NON-COMPLIANCE NATURE OF THE ENFORCEMENT PERSONNEL
VIOLATION RESPONSES
4. Inadequate record Inspector finds files - NOV PC
keeping incomplete to
missing (no evidence
of intent)
Recurring - AO PC
- Civil Action S, CA
5. Failure to report Inspection finds - NOV PC
additional monitoring additional files
Recurring - AO PC
- Civil Action S, CA
39
TIMEFRAMES FOR RESPONSES
A. All violations will be identified and documented within five (5) days of receiving
Notice of Violation. Violations of discharge limits will require notification within 24
hours of becoming aware of the exceedance.
S. Initial enforcement responses [involving contact with the industrial user and requesting
information or corrective or preventive action(s)] will occur within 15 days of Notice of
Violation.
C. Follow-up actions for continuing or re -occurring violations will be taken within 60 days
of the initial enforcement response. For all continuing violations, the response will
include a compliance schedule.
D. Violations which threaten health, property, or environmental quality are considered
emergencies and will receive immediate responses including, but not limited to, halting
the discharge or terminating service.
E. All violations meeting the criteria for significant non-compliance will be addressed with a
Notice of Violation within 30 days of the identification of significant noncompliance.
40
Chapter 6. Forms Used in Pre Treatment Program
INTRODUCTION
This Chapter contains the forms used by the City of Oshkosh in the management of the City's
Pre -Treatment Program.
FORM
PAGE
Pre -Treatment Industrial Survey 42
Questionnaire
Baseline Report 62
Industrial Wastewater Discharge Permit 66
Application
Industrial Inspection Survey 69
90 -Day Final Compliance Report 73
Sample Audit Sheet 74
41
PRE-TREATMENT PROGRAM INDUSTRIAL USER SURVEY
QUESTIONNAIRE
Please use black ink or typewriter
Section I — Publicly -Owned Treatment Works (POTW)
1. Name of POTW City of Oshkosh Wastewater Treatment Facility
2. Address 233 Campbell Road
3. POTW Representatives: Stephan Brand Iason Ellis
Title: Public Works Utility Manager Pre -Treatment Coordinator
Phone: (920) 232-5362 (920) 232-5374
Section II — Industrial User
A. Industrial User Identification
Industry Name:
1. Address: (Mailing)
2. City, State, Zip Code
3. Address: Location)
4. City, State, Zip Code
Parent Company
Address: (Mailing)
City, State, Zip Code
5. Industrial User Representative, Principal Executive Officer, Partner or Sole
Proprietor
Title:
Phone:
42
6. Industrial Contact Person
(Person familiar with processes and operations)
Title:
Phone:
7. Nature of Business
8. Principal Product(s)/Service(s)
9. Standard Industrial Classification Number (SIC)
10. Does the Industry have a spill prevention control and countermeasure plan in effect?
Yes No
Explain:
What chemicals are maintained in stock for spill prevention control?
11. Does this industry discharge Process Wastewater* to the Municipal Sewer(s)?
Yes No
'Process Wastewater means any water which, during manufacturing or processing, comes into direct contact with
or results from the production or use of raw material, intermediate product, byproduct, or waste product and is
likely to contain in solution or suspension various components of such raw materials and products.
Sanitary Discharge Only Septic Tank No Sewer
43
Important
If the answer on Process Wastewater is No please complete only Pages I and 2, sign below, and return
questionnaire as soon as possible. If process wastewater is discharged to the sewers, complete the entire
questionnaire and return as soon as possible.
Signature of Industry's Responsible Official:
Name: (Print)
Title:
Date Signed:
Date Returned:
44
B. Plant Operational Characteristics
Note: You may request that some information remain confidential. The POTW will have the
authority to decide whether this information should be classified as confidential. Submit the
information considered confidential on a separate sheet of paper and indicate this on the
questionnaire.
1. Provide a separate description of each different production process, which results in the
generation of a process wastewater discharge to the POTW. Be as concise as possible.
2. For each production process described in DLIindicate the amount of raw materials consumed
and the products manufactured per day during the month of maximum production, which is
representative of the expected level of activity contributing to this discharge. Levels of
production may be obtained from actual operating records or expected production levels
based on Market projections. Figures are to be reported in the appropriate units of
measurement given in Table 1 for the particular categories listed. Other categories should use
the units of measurement normally used by the industry.
Raw Materials
Products
Name
Maximum
Amount/Da
Unit
(Table 1)
Name
Maximum
Amount/Da
Unit
(Table -1)
45
Table 1
Units of Measurement Industry
Industry
Units of Measurement
Meat Products
LB LWK — (live weight killed)(meatpacking in slaughterhouse or
packinghouse, poultry processing)
LB — Product (slaughterhouse & rendering, processing)
LB — Raw material (rendering in offsite plant)
Dairy Products
1000 LB — milk equivalent
Canned and Preserved Fruits & Vegetables_
TON — raw material
Grain Mill Products
1000 BU — processed
Raw Cane Sugar
TON — sugar cane processed
Cane Sugar Refining
TON - raw sugar processed
Beet Sugar
TON — beets sliced
Wines, Brandy and Brandy Spirits
TON — grapes processed
1000 GAL — wine (table wine, for process season only)
Distilled Liquor, Except Brandy
1000 BU — grain processed
Bottled and Canned Soft Drinks
1000 standard cases
Seafoods
TON — raw materials
Textile Mill Products
1000 LB — raw materials or 1000 LB product
Sawmills and Planning Mills
1000 FPM
Veneer & Plywood
1000 ftz — on three-eighths basis
Wood Preserving
1000 ft3 — treated
Particle board
1000 ftz — on three quarter inch basis
Paper and Allied Products
TON — product
Inorganic Chemicals
TON — product
Plastic Metals and Synthetics Industry
1000 LB — product
Synthetic Rubber (Vulcanisable Elastomers)
1000 LB — rubber produced
Drugs and Pharmaceutics
1000 LB — raw material
Soap and Detergents
1000 LB — product or 1000 gal product
Organic Chemicals
1000 LB — product
Fertilizer Industry
1000 TON — product
Agricultural Chemicals and Pesticides
1000 LB — product
Petroleum Refining
1000 BBL — crude or partially refined feed stock (stream day)
Rubber Products
1000 LB — raw material
Leather Tanning & Finishing
1000 LB — green salted hides or pickled skins
Flat Glass & Glass Products made from purchased
Glass
1000 TON — product or 1000 ftz mirrored surface
Hydraulic Cement
1000 BBL — product
Concrete Gypsum & Plaster Products
1000 TON — product
Asbestos Products
1000 TON — asbestos used
Coke Making
TON — dry coal
Blast Furnace
TON — hot metal
Steelworks
TON — liquid steel
Hot Forming
TON — hot formed steel
Rolling & Finishing Mills
TON — processed steel
Iron & Steel Foundries
TON — metal cast
Primary Smelting & Refining of Nonferrous
Metals
1000 LB — metal product
Secondary Smelting & Refining of Nonferrous
Metals
1000 LB — metal product
Rolling, Drawing, & Extruding of Nonferrous
Metals Nonferrous Foundries
1000 LB — metal processed
Automobile Manufacturing
1000 LB — metal cast
Electric Power Services
1000 MWD — generated
Steam Supply
1 million -lb steam produced
46
3. Prepare a schematic diagram of the wastewater flow from each process line that is discharged
to the municipal sewers. Identify plant sewer outlets and indicate same on building layout
map, section II F. Indicate discharge permit numbers if applicable.
Figure A
(Example)
Schematic of Wastewater Flow
GPD = Gallons per Day
Name of Industry
Blue River Municipal Water Supply
100,000 GPD 30,000 GPD
55,000 45,000
GPD GPD
RawProcess 15,000 GPD process 20,000 GPD Washing R
Mtls. ppi,,,„.
40,000 GPD 40,000 GPD
Solid
Waste Grit Neutralization Loss 40,000 GPD
4,000 Separator Tank a°"""` 6,000 Disch. 4002
GPD GPD
34,000 GPD
36,000 GPD
47
To Atmosphere
5,000 GPD
Drying
Product
5,000 GPD
Waste
.
Treatment
70,000 GPD
Plant
Disch. 4001
47
To Atmosphere
5,000 GPD
Drying
Product
5,000 GPD
4. Discharge Period
(A) Discharge occurs daily: from
to
(B) Circle the days of the week that the discharge occurs: S M T W T F S
5. Variation of Operation Indicate whether the business activity is: Continuous throughout the
year, or seasonal. Circle the months of the year during which discharge occurs:
JFMAMJJASOND
(Indicate month of peak production)
Comments:
6. Wastewater Flow Rate
Peak Hourly
Max. Daily
Annual Daily Avg.
Avg. Daily
Avg. Daily
Gallon / Min
Gallon /Min
Gallon / Day
Seasonal Min.
Seasonal Max.
7. If Batch discharge, Indicate:
a. Number of batches discharged: per day; per week
b. Average quantity per batch: gallons.
c. Flow rate: gallons / minute.
8. Wastewater discharges determined by:
Meter (water or wastewater )
Estimate
48
9. Average number of employees per shift: 1st; 2nd; 3rd
Shift start times:
1st•
2nd
Indicate with a check mark the shifts normally worked each day:
3rd
Is there a scheduled shutdown? When?
C. Wastewater Characteristics
Wastewater Strength Estimates: Enter the average annual and maximum wastewater
strength for each of the following elements of wastewater strength:
mg/1= milligrams per liter
Elements of wastewater strength
Sunday
Monday
Tuesday
Wednesday
Thursday
Friday
Saturday
Ism
Oil & Grease (mg/1)
Phosphorus (mg/1)
pH
2ND
Temperature (fahrenheit)
3RD
Is there a scheduled shutdown? When?
C. Wastewater Characteristics
Wastewater Strength Estimates: Enter the average annual and maximum wastewater
strength for each of the following elements of wastewater strength:
mg/1= milligrams per liter
Elements of wastewater strength
Average
Maximum
Suspended Solids (mg/1)
BOD (mg/1)
Oil & Grease (mg/1)
Phosphorus (mg/1)
pH
Temperature (fahrenheit)
49
2. Wastewater Constituents: Indicate if any of the following constituents can be present in the
wastewater discharged from the facility and the concentration, if known.
Constituents
Constituents
Constituents
Algaecide
Cyanide
Potassium
Aluminum
Fluoride
Radioactivity
Ammonia
Formaldehyde
Selenium
Antimony
Halogenated Organics*
Silver
Arsenic
Hydrocarbons*
Sodium
Asbestos
Iodine
Solvents*
Barium
Iron
Sulfate
Beryllium
Lead
Sulfide
Boron
Magnesium
Sulfite
Bromide
Manganese
Surfactant MBAS
Cadmium
Mercury
Thallium
Calcium
Molybdenum
Titanium
Chlorine
Nickel
Tin
Chloride
Oil & Grease (Min)
Vanadium
Chromium
Oil & Grease (Total)
Volatile Acids
Cobalt
Pesticides*
Zinc
Copper
Phenols
Others
Identify the Chemical Compounds or Elements
Comments:
50
3. Toxic Pollutants: Are any of the toxic pollutants listed in Table 2 being used at this facility in
manufacturing of the product or are any of these pollutants a by-product, which may be
discharged? If yes, please indicate by a check mark alongside the pollutant.
List any other toxicant known of anticipated to be present in the discharge
4. Describe the basis for the analytical data presented in D.1 through D.3; describe sampling
locations, equipment, etc.
5. Are flow monitoring records available?
6. Are wastewater sampling records available?
7. List any pollutants which are known or anticipated to be present in the discharge that may:
a. Create a fire or explosive hazard
b. Cause corrosive structural
c. Be solid or viscous and present in amounts which may cause obstruction to the flow in
sewers or any other interference with the operation of the POTW
51
TABLE 2
65 TOXIC POLLUTANTS LISTED IN NRDC CONSENT DECREE AND
REFERENCED IN 307(a) OF THE CWA OF 1977
Acenapthene
Acrolein
Acrylonitrile
Aldrin / Dieldrin
Antimony and compounds
Asbestos
Benzine
Benzidine
Beryllium and compounds
Cadmium and compounds
Carbon tetrachloride
Chlordane
Chlorinated benzene
Chlorinated ethane
Chloralkyl ethers
Chlorinated naphthalene
Chlorinated phenols
Chloroform
2 -chlorophenol
Chromium and compounds
Copper and compounds
Cyanide
DDT and metabolites
Dichlorobenzene
Dichlorobenzidine
Dichloroethylene
2,4 -dimethylphenol
Dichloropropane & Dichloropropene
2,4 -dimethylphenol
Dinitrotoluene
Diphenylhydrazine
Endosulfan and metabolites
Endrin and metabolites
Ethylbenzene
Fluoranthene
Haloethers
Halomethanes
Heptachlor and metabolites
Hexachlorabutadiene
Hexachlorocyclohexane
Isophorone
Lead and compounds
Mercury and compounds
Napthalene
Nickel and compounds
Nitrobenzene
Nitropenols
Nitrosamines
Pentachlorophenol
Phenol
Phthalate esters
Polychlorinated biphenyls (PCB's)
Polynuclear aromatic hydrocarbons
Selenium and compounds
Silver and compounds
2,3,7,8-tetrachlorodibenzop-dioxin (TCDD)
Tetrachloroethylene
Thallium and compounds
Toluene
Toxaphene
Trichloroethylene
Vinyl chloride
Zinc and compounds
52
TYPICAL SEWER DISCHARGE ANALYSIS
FOR VARIOUS INDUSTRY CATEGORIES
Type of Industry
pH
Hex
Sol
BOD
TSS
Vol
SS
CN
(T)
Zn
(T)
Cd
(T)
Cu
(T)
Cr
(T)
Hex
Cr
Fe
Ni
Pb
Se
Hg
Metal Platers
X
X
X
X
X
X
X
X
X
X
X
X
X
Meat Packers
X
X
X
Food Industry
X
X
X
Tanneries
X
X
X
X
X
Chemical
X
X
X
X
X
X
X
X
X
X
X
X
X
Laundry
X
X
X
X
X
Petroleum
X
X
X
X
X
X
X
X
X
X
X
X
X
Machine
X
X
X
X
X
X
X
X
X
X
X
X
X
Steel Mill
X
X
X
X
X
X
X
X
X
X
X
X
X
Dairy
X
X
X
Heat Treaters
X
X
X
X
X
X
X
X
X
X
X
X
X
Paper Mfg.
X
X
X
X
Paint Mfg.
X
X
X
X
X
X
X
X
X
X
X
Coke Mfg.
X
X
X
X
X
Rendering Plant
X
X
X
D. Water Use and Disposition
1. Describe any water treatment processes in use. List chemical brand names of products used
for water treatment, boiler treatment, degreasing, cleaning operations, etc.
53
2. Complete the following table; use estimates if necessary. If no other information is available,
use 20 gallons / person / shift as an average sanitary waste volume.
Note:
1. Enter the quantity and the appropriate code letter indicating the source:
(a) well, (b) creek, (c) storm water, (d) reclaimed water
2. Enter the quantity and the appropriate code letter indicating the discharge point:
(a) well, (b) creek, (c) storm drain, (d) rail, truck, (e) evaporation, (f) product
3. Describe
54
Supplied
From
Discharged To
Municipal
Other (1)
Municipal sewer
Other (2)
Water used for
Gal / day
Gal / day
Source
Gal / day
Gal / day
Discharge to
Sanitary
Processes
Cooling
Washing
Irrigation
Product
Other (3)
Note:
1. Enter the quantity and the appropriate code letter indicating the source:
(a) well, (b) creek, (c) storm water, (d) reclaimed water
2. Enter the quantity and the appropriate code letter indicating the discharge point:
(a) well, (b) creek, (c) storm drain, (d) rail, truck, (e) evaporation, (f) product
3. Describe
54
E. Pollution Abatement and Wastewater Pre -Treatment
1. Pollution Abatement Practices
None Holding Tank Grease Trap Oil & Water Separator
Grinding Sedimentation pH Adjustment Biological Treatment
Screening Chlorination Other
2. Describe sludge treatment and disposal methods in effect for this facility.
3. Describe any changes in treatment or disposal methods planned or under construction for the
wastewater or sludge:
4. Is this facility subject to an existing Pre -Treatment Standard?
5. Are additional pretreatment faculties and / or operation and maintenance required to meet
Pre -Treatment Standards? If additional pre-treatment and / or operation and maintenance
are required, provide the schedule by which they will be
provided:
6. Is an engineering report on the pre-treatment system available?
55
7. Has the Industry's discharge ever upset or interfered with the operations at the POTW?
If yes, list responsible pollutant(s)
56
F. Building Layout
Draw the location of each building on the premises. Show the location of all water meters, storm
drains, and each building sewer. Include local street information and a north arrow. See sample copy
attached. If existing drawings are available, please submit copy in lieu of diagram below.
Company Name:
Address:
57
—N
SAMPLE COPY
Company Name
Sanitary Main
58
Section III - Code Identification
For each process used at the factory, list the appropriate code on the line provided. The specific NR
subcategory numbers are required. If you need assistance, please call either the POTW representative
or the Wisconsin Department of Natural Resources.
To be completed jointly by the POTW and the Industrial User. See attached NR code sheet for general
category identification.
Process NR Code Process NR Code
Section IV - Signatures
Signature of POTW representative
Title
Date Signed
The information contained in this questionnaire is familiar to me and to the best of my knowledge and
belief, such information is true, complete and accurate.
Signature of Industry's responsible official
Title
Date signed
Date returned
59
Wisconsin Pollutant Discharge Elimination System
(Selected Codes - NR 200 to 297)
NR 200 Application for discharge permits
NR 239 Carbon black manufacturing
NR 201 Fact sheet for proposed permits
NR 240 Dairy products processing
NR 202 Report of industrial waste contribution to
Municipal systems
NR 245 Grain mills
NR 205 General provisions
NR 247 Glass manufacturing
NR 210 Sewage treatment works
NR 250 Hospital
NR 211 General Pretreatment Requirements
NR 252 Leather tanning and finishing
NR 214 Land disposal of liquid wastes
NR 253 Copper Forming
NR 215 List of Toxic, Conventional, and
Nonconventional Pollutants
NR 254 Iron and Steel manufacturing
NR 216 Storm Water Discharge Pernits
NR 255 Battery Manufacturing
NR 217 Effluent Standards and Limtitations
For Phosphorus
NR 256 Metal Molding and Casting
NR 218 Method and manner of sampling
NR 257 Aluminum Forming
NR 219 Analytical test methods and procedures
NR 258 Meat products
NR 220 Categories and classes of point sources
NR 260 Electroplating
NR 221 Asbestos manufacturing
NR 261 Metal finishing
NR 225 Canned and preserved fruits and vegetables
NR 262 Porcelain Enameling
NR 228 Cement manufacturing
NR 263 Coil Coating
NR 230 Inorganic chemical manufacturing
NR 264 Electrical and Electronic Components
NR 231 Explosives manufacturing
NR 268 Coal mining
NR 233 Pesticide Chemicals
NR 269 Stone, gravel and sand segment of
mineral mining and processing
NR 235 Organic chemical manufacturing
NR 274 Non-ferrous metals manufacturing
NR 236 Gum and wood chemicals manufacturing
NR 275 Paving and roofing materials
NR 237 Pharmaceutical Manufacturing
NR 276 Phosphate manufacturing
60
Wisconsin Pollutant Discharge Elimination System
(Selected Codes - NR 200 to 297)
(Continued)
NR 277 Photographic processing
NR 279 Petroleum refining
NR 280 Plastics and synthetics
NR 281 Paint and ink formation
NR 286 Rubber processing
NR 290 Steam electric power generating
NR 294 Soap and detergent manufacturing
NR 295 Sugar processing
NR 296 Textiles
NR 297 Timber products
61
1
BASELINE REPORT
Identifying Information
a. Name of Facility
b. Address
c. Name of Ind. Contact person
2. Permits
a. List environmental control permits held by facility:
3. Description of Operations
a. Nature of operation
b. Average rate of production
Date:
Title
c. SIC code
d. Attach a schematic diagram of the sewer system. Include locations, process
labeling, domestic labeling and average gallon per day use at point of entrance into
factory sewer system and public sewer system.
4. Summary of sewer use
a. Number of days per year in operation
b. Number of shifts per day
c. Number of employees per shift
d. Industrial use
(1) Process Name
Discharge Volume and Frequency (GPD or Batch)
(2) Process Name
62
e
Discharge Volume and Frequency (GPD or Batch)
(3) Process Name
Discharge Volume and Frequency (GPD or Batch)
(4) Process Name
Discharge Volume and Frequency (GPD or Batch)
(5) Process Name
Discharge Volume and Frequency (GPD or Batch)
Domestic use (20 gpd x # of employees)
5. Characteristics of wastewater controlled by pretreatment regulations. (Fill out sheet
for each controlled process.)
a. Process wastewater from
b. Regulation
c. Sampling Point
d. Type of Sample (composite/grab)
e. Gallons discharged
f. Element and concentration of pretreatment regulated parameters
(Three samples required within two week period if flow is less than 250,000 gpd.
If sampling is performed by City of Oshkosh contracted lab, results may be
submitted directly to Pre -Treatment Coordinator in lieu of filling in table below.)
Element
1St
Sample
Date
2nd
Sample
Date
3=d
Sample
Date
Daily
Maximum
Average
g. Toxic organic compounds used: Yes No
63
(Toxic organic sources may occur in solvents, lubricants, paint stripping, surfactant
preparations, and surface coating. Check labels of compounds used.)
(1) If used but not discharged, the following shall be filled out as an alternative to
testing for TTOs.
(a) Initial compliance date:
(b) Method of disposal:
Transporter:
Destination:
(c) Toxic organic management plan in place as required Yes No
(1) If Yes, furnish a copy with report (enclosed)
(2) If No, date that a plan will be in place and copy will be sent to City
(d) Certification statement as required by 40 CFR Sec. 469.13 (c)
"Based on my inquiry of the person or persons directly responsible for
managing compliance with the pre-treatment standard for total toxic
organics (TTOs), I certify that to the best of my knowledge and belief, no
dumping of concentrated toxic organics into the wastewater has occurred
since filing of the latest semi-annual compliance report. I further certify that
this facility is implementing the solvent management plan submitted to the
Control Authority."
Signature Title
(3) If TTOs are used and discharged, the following shall be filled out:
Trade Name TTO Amount Used Where Used
Compound
6. Certification of sampling and testing Laboratory
a. Name of Laboratory
64
b. Address of Laboratory
c. Telephone Number
d. Method of Analysis
e. I certify that all sampling and analysis was performed as per EPA methodologies.
(Signature of Qualified Professional) Title Date
7. Certification of President or Vice President of Company
a. Pre -Treatment standards are being met consistently: Yes No
b. If No, list below increments of progress towards compliance. (A report of
increment/milestone completion is required within two weeks of completion.)
(1) Date
(2) Date
(3) Date
c. Date of Final Compliance
Signature
65
Title Date
CITY OF OSHKOSH
INDUSTRIAL WASTEWATER DISCHARGE PROGRAM
INDUSTRIAL WASTEWATER DISCHARGE PERMIT APPLICATION
(Industry Name)
By submittal of this application and baseline reports requests a permit to discharge
wastewater to the sanitary sewer according to Chapter 24 of the Municipal Code of the City of
Oshkosh.
This industry's physical facility is located at
and is presently engaged in (state nature of business
at the above location.
Mailing Address:
Name of Parent Company.
Parent Co. Mailing Address:
All industries must submit a separate application and baseline report for each facility.
All applicants must attach a complete 'INDUSTRIAL USER — PRETREATMENT BASELINE
REPORT FORM for each facility (see separate instructions).
In consideration of the granting of this permit, the undersigned agrees:
1. To furnish any additional information relating to the installation or use of the
industrial sewer for which this permit is sought as may be requested by the City of
Oshkosh.
2. To accept and abide by all provisions of Chapter 24 of the Municipal Code of the City
of Oshkosh, and all other pertinent City Code or State and Federal regulations that
may be adopted in the future.
66
3. To operate and maintain any wastewater pretreatment facilities, as may be
required as a condition of the acceptance into the wastewater treatment system of
the industrial wastes involved, in an efficient manner at all times, and at no
expense to the City.
4. To cooperate at all times with the City and its representatives in their inspecting,
sampling, and study of the industrial wastes, and any facilities provided for pre-
treatment.
5. To notify the City immediately in the event of any accident, or other occurrence
that results in discharge to the wastewater treatment system of any wastewater or
substances prohibited by this permit.
6. To notify the City of any planned changes in production or processes, which may
alter their wastewater characteristics.
INDUSTRIAL USER REPRESENTATIVE
Principal Executive Officer, Partner or Owner (Print)
Title:
Telephone number:
Industrial Contact Person (Print)
Title:
Telephone number:
67
The information contained in this Application is familiar to me and to the best of my
knowledge and belief such information is true, complete and accurate. I understand that
falsification and/or deliberate misrepresentation of such information may subject me and the
industry I represent to civil and criminal penalties under Federal, State and local laws,
regulations and ordinances.
Signature of Industry's Responsible Official Title
Date
Please make check payable to "City of Oshkosh" and return fee and application to:
$20 Permit Application Fee Paid
Oshkosh WWTP
Attn: Jason Ellis
233 N. Campbell Rd
Oshkosh, WI 54902
Acknowledgement of Payment Date
68
CITY OF OSHKOSH
INDUSTRIAL INSPECTION SURVEY
NAME OF INDUSTRY
LOCATION
CONTACTED
NO. OF SHIFTS APPROXIMATE NO. EMPLOYEES
DISCHARGE FLOW
WATER SOURCES
INDUSTRIAL DESCRIPTION
PRINCIPAL PRODUCTS
PRE-TREATMENT CAPABILITIES
(1) PERSONNEL IN CHARGE
(2) PERSONNEL TRAINING
(3) SLUDGE OR RESIDUE DISPOSAL
69
S.LC#
PHONE
TIME
(4) SHIPPING MANIFESTS (REVIEW)
(5) SAMPLING POINT
PRIMARY USES FOR WATER
HEATING & COOLING SYSTEMS
INDUSTRIAL HEATING & COOLING
SEWER CONNECTIONS:
NUMBER SANITARY NUMBER STORM
SAMPLING POINTS
DISCHARGES OTHER THAN SEWER
SLUDGE OR RESIDUE DISPOSAL
2. SHIPPING MANIFESTS (REVIEW)
SITE INSPECTION
INSIDE
2 OUTSIDE
70
3 STORAGE OF CHEMICALS
4 IS A SLUG PREVENTION/SPILL PLAN NEEDED? YES NO
IF YES, IS CURRENT PLAN ON FILE?
5 EMERGENCY PHONE NUMBERS POSTED
CHANGES IN OPERATION
ACTIONS
REMARKS
ORDERS
71
REINSPECTION DATE FINAL INSPECTION
INSPECTOR
IND. CONTACT
72
TITLE
90 -DAY FINAL COMPLIANCE REPORT
TO: City of Oshkosh Pretreatment Program Coordinator
FROM: 90 -Day Final Compliance Report as required by 40 CFR 403.12 (d),
NR 211.15 (3), and Section 24-6.3 (F) (1) of the Municipal Code of the City of
Oshkosh.
1. Nature and concentration of all pollutants in the discharge from all regulated
processes which are limited by pre-treatment standards and requirements, and the
average and maximum daily flows for those process units which are limited by such
pre-treatment standards and requirements.
2. All applicable pre-treatment standards are being met consistently: Yes No
3. If pre-treatment standards are not being met consistently, describe what operational or
maintenance procedures are required to meet standards.
a.
b.
C.
d.
4. Increments of progress towards compliance and dates:
a. Date:
b. Date:
C. Date:
Date of compliance:
Signature:
Date:
Title:
73
SAMPLE AUDIT SHEET
TO: (Contact Name)
FROM: Jason Ellis, Pre -Treatment Coordinator
SUBJECT: Audit of (current year) Pre-treatment Program charges to industry and
estimate of (next year) charges including adjustments.
FOR: (Industry Name)
Current Year Charges
(Current Year) Estimated Sampling Charge: 0.00
(Current Year) Actual Charges Invoice # Date Amount
Total of actual cost incurred: 0.00
Next Year Estimated Charges
The difference between actual and estimated: 0.00
Estimated sampling charge per bid:
Fixed cost share per formulae:
Total Estimated Cost:
2018 (+/-) Adjustments: 0.00
Total Estimated Cost plus Adjustments: 0.00
2019 BILLINGS: April 1, 2018 0.00
October 1, 2019 0.00
"Formula for figuring Industrial Fixed Charges share:
(Estimated S&A charge / Total Industrial S&A charge) x (City's Fixed Cost) = Fixed Cost Share
74