Information
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Program
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Wastewater Treatment Application
Local Limits
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Questionnaire | Enforcement Response
| Surcharges
Hauled Wastes & Special Discharges |
Waste Hauler Tracking Form
Compliance Schedules |
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| In the event an existing
non-domestic contributor is unable to meet newly established
discharge limitations, an interim discharge limit may be
established. The interim limit will require the
contributor to exercise more care and control over the
discharge than is presently being done. Increased
monitoring and reporting will also be required during the
interim period.
If additional pretreatment and/or modifications to operations and/or maintenance (O&M) will be required to meet the pretreatment standards, the non-domestic contributor will provide such additional pretreatment and/or O&M by the shortest compliance schedule reasonably achievable. The completion date in this schedule shall not be later than the compliance date established for the applicable pretreatment standard. The following conditions shall apply to the required compliance schedule. |
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| * | The schedule shall contain increments of progress in the form of dates for the commencement and completion of major events leading to the construction and operation of additional pretreatment required for the non-domestic contributor to meet the applicable pretreatment standards (e.g. hiring an engineer, completing preliminary plans, completing final plans, executing contract for major components, commencing construction, completing construction, etc.). |
| * | No increment referred to in the previous paragraph shall exceed nine months. |
| * | Not later than 14 days following each date in the schedule and the final date for compliance, the non-domestic contributor shall submit a progress report to the Control Authority including, at a minimum, whether or not it complied with the increment of progress to be met on such date and, if not, the date on which it expects to comply with this increment of progress, the reason for delay and the steps being taken by the non-domestic contributor to return the construction to the schedule established. In no event shall more than nine months elapse between such progress reports to the City. |
| The compliance schedule shall become a part of the contributor’s
pretreatment permit.
Discharges from new sources or modifications to existing facilities must meet all discharge requirements prior to any discharge from the new or modified facilities. |
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Inspections |
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| All Significant Industrial Users (including Categorical Users) will be inspected at least annually. Minor Non-Domestic Users will be inspected once every two years at a minimum. City staff will go onto and/or have guided access to each contributor’s premises at all times to carry out all necessary surveillance and monitoring responsibilities. Representatives of the City Water and Pollution Control Department shall be authorized to enter any premises of any non-domestic contributor in which a discharge source or treatment system is located or in which required records are kept to assure compliance with pretreatment standards. The City will schedule the inspections in advance except when advance notice is not possible or practical (such as an emergency, unforeseen event, or possible legal or administrative action). The contributor may request splits of samples taken during the inspections. However, the results of samples taken by the City and analyzed in a certified laboratory will be used to evaluate compliance with the pretreatment permit and program requirements. | |
Slug Discharge Control Plans |
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| Significant Industrial Users
will be evaluated annually, and minor non-domestic
contributors will be evaluated at least once every two years
to determine if a slug control plan is required. A slug discharge is defined as any discharge of a non-routine, episodic nature, including, but not limited to, an accidental spill or a non-customary batch discharge. The results of such activities shall be available to the City immediately upon request. If it is determined that a slug control plan is needed, the plan shall contain, at a minimum, the following elements: |
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| 1. | A description of discharge and disposal practices, including non-routine batch discharges |
| 2. | A listing of stored chemicals, including the manner and location in which they are stored (note if stored near a sink or floor drain and if secondary containment is provided) |
| 3. | Procedures for immediately notifying the City Water and Pollution Control Department of slug discharges, including any discharge that would violate a prohibition under 40 CFR 403.5(b), with procedures for follow-up written notification within five days |
| 4. | If necessary, procedures to prevent adverse impact to the City Water Pollution Control Facility 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 or equipment, measures for containing toxic organic pollutants (including solvents), and/or measures and equipment for emergency response |
Enforcement Response Plan |
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| Federal regulations (40
CFR 403.8(5)) require that the City develop an
Enforcement Response Plan
containing detailed procedures for investigation and
response to instances of non-domestic contributor
non-compliance with pretreatment regulations.
Chapter 28 of the Ames Municipal Code (ordinance) gives
the Director of the Ames Water Pollution Control Department
and any designee the authority to implement and enforce the
Enforcement Response Plan. Examples of non-compliance with pretreatment program requirements include, but are not limited to, unpermitted discharges, exceeding discharge limits, failure to monitor as required, and/or failure to report as required. Instances of non-compliance may be identified through self-monitoring reports submitted by non-domestic contributors, City monitoring results, inspections by City or other governmental staff, or through notification of non-compliant situations (such as spills, illegal discharges, etc.) by the contributor, city staff, other governmental employees or by concerned citizens. When an instance of non-compliance is suspected, the incident will be identified and documented to determine if a violation of the pretreatment requirements has occurred. A pretreatment coordinator will investigate the alleged violation. Documentation of the investigation, including letters, telephone call memos, e-mails, meeting notes, and/or inspection notes, will be maintained by City staff. If a violation has occurred, appropriate enforcement action will be taken by city staff. Examples of the types of escalating enforcement actions the City will take are outlined in the Enforcement Response Plan (ERP). The ERP is intended to be a guide and will be followed as closely as individual circumstances allow. Any alleged violation which has the potential to threaten health, safety, property, or environmental quality will be investigated immediately. |
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Description of Enforcement Responses |
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| Initial enforcement responses will generally involve a Notice of
Violation (NOV). An NOV may be a documented telephone call, an
e-mail, or a letter from the City to the contributor stating the
nature of the violation and recommended or required actions.
If needed, the City will work with the contributor to develop a
compliance schedule. If the violation results in costs to the
City for increased staff time or additional resources, the costs may
be assessed back to the violating facility. When the City determines a need for stronger enforcement response, a municipal infraction may be issued. Municipal infractions carry fines up to $1,000 per day per violation. If further enforcement actions are required, the City may terminate service or obtain a court order for the contributor to amend, halt, or cease certain operations. Criminal penalties may be sought for violations such as falsification of data or records, tampering with sampling equipment, knowingly violating the discharge permit, etc. The City may recover from the contributor damages to the City caused by the instance of non-compliance, including, but not limited to, any penalties, fines, additional City staff time or resources, or other damages for which the City becomes liable as a result of the instance of non-compliance. |
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Significant Non-compliance |
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| A non-domestic contributor is in significant non-compliance if any violation meets one or more of the following criteria as listed in 40 CFR 403.8(f)(2)(viii). | |
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Public Reporting |
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| The City must comply with the public notification requirements of 40 CFR Part 25 in the enforcement of national pretreatment standards. The required procedures include provisions for at least annual public notification, in the largest daily newspaper published in the municipality in which the POTW is located, of any significant non-compliance with applicable pretreatment requirements. | |
Reporting to the IDNR/U.S. EPA |
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| The City submits an annual report to the IDNR/U.S. EPA covering the pretreatment program. The report is a summary of pretreatment activities associated with all Significant Industrial Users under the City of Ames pretreatment program. It is submitted in the format and with the information required by the regulatory agency. | |