POTW Program Development and Revision

CWACS will put together an approvable pretreatment program for submittal to the Approval Authority (EPA or state).  In addition, many municipal governments may be able to negotiate partial pretreatment programs.  This allows the municipal government to meet the objectives of the pretreatment program while avoiding developing a full or approved pretreatment program.  CWACS can facilitate this discussion and provide programmatic solutions to satisfy both the municipality and EPA or state staff. 

This project may include all or some of the following: 

1.  Development of Ordinance/Rules and Regulations
2.  Design of Sampling Plan for Local Limits
3.  Completing an Industrial Waste Survey
4.  Calculation and Incorporation of Local Limits
5.  Development of a Permit Boilerplate
6.  Development of Best Management Plans, where necessary
7.  Evaluating and Designing special programs (e.g. Hauled Waste, Oil and Grease, Tracking Slug Discharges)
8.  Data Management (Manual or Computerized) based upon program size
9.  Putting together an Enforcement Response Plan
10.  Inter-jurisdictional Agreements
11.  Standard Operating Procedures specific for your POTW.
12.  Calculating Technically-based Surcharge Rates

Local Limits

Legally defensible and technically-based  Local Limits are critical to your program.  Curt McCormick authored the EPA Region 8 Strategy for Local Limits and has refined many aspects of the original document based upon litigation and newer technology.  A local limits study and revision may include some or all of the following:

1.  Evaluation of Historical Data
2.  Compilation of Pollutants where Additional Monitoring is Required
3.  Review/Compilation of POTW and Receiving Water Information with Review of NPDES Permit Basis
4.  Calculating Local Limits
5.  Establishing Appropriate Limits/BMPs
6.  Developing Legal Authority Language
7.  Putting together the Approval Request
8.  Follow-up to Address Issues (Approval Authority questions, public notice comments, etc)

1.  Update POTW Legal Authority
2.  Update SIU/IU Permit and Fact Sheet Boilerplates
3.  Update Compliance Monitoring Procedures
4.  Assist in Development of BMPs

Preliminary Program Evaluation (Pre-Inspection Review)

Before the State or EPA come in to inspect your program, let CWACS do a review.  It will minimize any potential deficiencies reducing your future workload and keeping you out of the system.  This is your opportunity to fix problems before they become problems.

Includes on-site work that may include some or all of the following:

1.  Legal Authority Review
2.  Confirmation of Industrial Waste Survey
3.  Industrial User Permit Quality
4.  Industrial User Inspection Quality 
5.  Local Limits (Are they good)?
6.  Enforcement Response to Violations
7.  File Documentation
8.  Self Monitoring Report Reviews
9.  Compliance Monitoring Program
 

Other Services

CWACS will work with NPDES permit holders to ensure that permits are appropriately developed and issued.  States are required to document all permit decisions in the Statement of Basis or Fact Sheet.  Decisions on permit limits and requirements are based upon the permit application and historical data.  In addition, there is often a desire to include conditions based upon policy and guidance.  The permittee must ensure that these conditions are reasonable and clearly established.  The permittee should always look for alternative approaches that achieve the same outcome as desired by the permitting authority. 

CWACS will provide support in the following areas:

Regulatory and Policy Consultation and Review
Review of Proposed Local, State and Federal Rules and Regulation
NPDES and state wastewater permitting
Water Quality Standards Application
Methylmercury Tissue Water Quality Standards Implementation

In addition, CWACS will provide support for Preparing Agency Reports, Industrial User Permitting, Training, Industrial User Inspections, Program Operation/Management, Best Management Practices (BMP) Development, Mercury BMPs, Legal Authority Development and Review, and Industrial User Surveys.