"Implementation Procedures Evaluation Checklist" - Oregon

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Oregon DEQ Industrial Pretreatment Program
IMPLEMENTATION PROCEDURES EVALUATION CHECKLIST
Name of POTW:
Date of Review:
Requirement
YES
NO
N/A
Section Reference
I.
Identification and Location of All Possible IUs of the
POTW [40 CFR Part 403.8(f)(2)(i)]
Adequate
Revision
Revision
Required
Recommended
A. Does the implementation procedures document describe
how the original, or most recent, complete IU survey was
conducted?
If YES:
1. Does it adequately describe the information sources
used to conduct the IU survey?
2. Was the survey sufficiently comprehensive to identify
all potential nondomestic users, including users
located outside of the POTW’s jurisdiction, and
mobile sources?
B. Does the document describe the IU classification process
to be used by the POTW?
If YES:
1. Is the POTW’s definition of “significant industrial
user” consistent with 40 CFR Part 403.3(t)?
2. Does the document describe procedures for
identification and categorization of IUs subject to
EPA’s categorical pretreatment standards?
3. Does it describe procedures for categorizing
“nondischarging” categorical users?
C. Does the document describe the POTW’s procedures for
updating the IU survey?
If YES:
1. Does it indicate that the survey will be updated on at
least an annual basis?
2. If applicable, does it describe how potential users will
be located in service areas outside the POTW’s
jurisdiction?
3. Does it describe the information sources (e.g.,
business license, billing records, etc.) to be used in
updating the survey described?
If YES, are these sources adequate?
4. Does it describe procedures for identifying users
located on leased property and/or mobile sources?
PPD\WC15\WC15342.DOC
Oregon DEQ Industrial Pretreatment Program
IMPLEMENTATION PROCEDURES EVALUATION CHECKLIST
Name of POTW:
Date of Review:
Requirement
YES
NO
N/A
Section Reference
I.
Identification and Location of All Possible IUs of the
POTW [40 CFR Part 403.8(f)(2)(i)]
Adequate
Revision
Revision
Required
Recommended
A. Does the implementation procedures document describe
how the original, or most recent, complete IU survey was
conducted?
If YES:
1. Does it adequately describe the information sources
used to conduct the IU survey?
2. Was the survey sufficiently comprehensive to identify
all potential nondomestic users, including users
located outside of the POTW’s jurisdiction, and
mobile sources?
B. Does the document describe the IU classification process
to be used by the POTW?
If YES:
1. Is the POTW’s definition of “significant industrial
user” consistent with 40 CFR Part 403.3(t)?
2. Does the document describe procedures for
identification and categorization of IUs subject to
EPA’s categorical pretreatment standards?
3. Does it describe procedures for categorizing
“nondischarging” categorical users?
C. Does the document describe the POTW’s procedures for
updating the IU survey?
If YES:
1. Does it indicate that the survey will be updated on at
least an annual basis?
2. If applicable, does it describe how potential users will
be located in service areas outside the POTW’s
jurisdiction?
3. Does it describe the information sources (e.g.,
business license, billing records, etc.) to be used in
updating the survey described?
If YES, are these sources adequate?
4. Does it describe procedures for identifying users
located on leased property and/or mobile sources?
PPD\WC15\WC15342.DOC
IMPLEMENTATION PROCEDURES EVALUATION CHECKLIST
continued
Requirement
YES
NO
N/A
Section Reference
D. Does the document indicate the manner in which the
information regarding the update will be provided to DEQ
(e.g., highlighted in POTW annual report?)
II. Evaluation of the Character and Volume of Pollutants
Contributed by IUs [40 CFR Part 403.8(f)(2)(ii)]
Adequate
Revision
Revision
Required
Recommended
A. Does the document indicate that completed questionnaires
or survey forms will be required from all “industrial
users” (SIUs and non-SIUs)?
If YES, is the questionnaire or survey form adequate to
gather basic discharge information and to determine if
additional investigation is warranted?
If NO, does the document describe other methods for
obtaining basic discharge information from all possible
“industrial users”?
B. Does the document indicate that completed “permit
application forms,” or similar documents, will be required
from all potential SIUs?
If YES, is the permit application form (or similar
document) adequate to fully characterize the character and
volume of pollutants discharged by an SIU?
If NO, does the document describe other methods for
obtaining detailed discharge information from all possible
SIUs?
C. Does the document indicate that inspections or site visits
will be conducted to verify information obtained on the
questionnaires and/or permit applications?
III. Notification of All IUs of the Regulations that Must be
Met [40 CFR Part 403.8(f)(2)(iii)]
Adequate
Revision
Revision
Required
Recommended
A. Does the document indicate that all SIUs will be issued
control mechanisms (permits) that contain all applicable
requirements specific to each user?
B. Does the document indicate how non-SIUs will be
notified of applicable requirements? [Note: DEQ
strongly suggests the use of “notification packages” for
this purpose.]
PPD\WC15\WC15342.DOC
- 2 -
IMPLEMENTATION PROCEDURES EVALUATION CHECKLIST
continued
Requirement
YES
NO
N/A
Section Reference
IV. Drafting and Issuance of IU Permits (including permit
contents) [40 CFR Part 403.8(f)(1)(iii)]
Adequate
Revision
Revision
Required
Recommended
A. Does the document provide a copy of the permit
application (or similar document) that will be used by the
POTW?
If YES, does the application contain all of the elements of
a “baseline monitoring report”? [40 CFR Part 403.12(b)]
B. Does the document provide a copy of the permit form that
will be used by the POTW?
If YES, complete the DEQ Permit Evaluation Checklist
and attach the checklist to this form.
C. Does the document adequately describe procedures for the
following components of the POTW’s proposed permit
program?
1. Permit application?
2. Drafting of permit?
3. Issuance of permit?
4. Permit appeal process?
5. Permit modification?
6. Permit reapplication?
7. Permit reissuance?
D. Does the document clearly identify the staff position
responsible for each element of the permit issuance and
renewal process, including permit signatories?
E. Does the document indicate that the POTW will use “fact
sheets” (or similar documents) to document permit
decisions (e.g., IU categorization, monitoring locations,
monitoring frequencies)?
V. Receipt and Evaluation of IU Reports and
Notifications [40 CFR Part 403.8(f)(2)(iv)]
Adequate
Revision
Revision
Required
Recommended
A. Does the document describe specific procedures to track,
receive, and review all IU reports and notifications in a
timely manner, including:
1. Baseline monitoring reports?
2. 90-day (“final”) compliance reports?
3. Periodic compliance reports?
4. Compliance schedule reports?
PPD\WC15\WC15342.DOC
- 3 -
IMPLEMENTATION PROCEDURES EVALUATION CHECKLIST
continued
Requirement
YES
NO
N/A
Section Reference
5. 24-hour notification of noncompliance?
6. 30-day re-sampling reports (violations)?
7. Notice of accidental spills or slugs?
8. Notice of changed production rates?
9. Notice of “authorized signatory” change?
10. Notice of ownership change?
11. Notice of bypass or upset?
B. Does the document clearly identify the staff position(s)
responsible for tracking, receipt, and review of each of the
required IU reports and notifications?
C. Does the document indicate the POTW will require IUs to
use standardized reporting or notification forms (i.e.,
forms developed by the POTW)?
If YES, do the forms adequately address all 40 CFR Part
403.12 reporting requirements, including signatory and
certification requirements?
D. Does the document clearly describe procedures for
identifying reporting and notification of violations, and
how such violations will be addressed by the POTW’s
enforcement program or does it cross-reference the
Enforcement Response Plan (ERP)?
VI. Sampling and Inspection of IUs to Ensure Compliance
[40 CFR Part 403.8(f)(2)(v)]
Adequate
Revision
Revision
Required
Recommended
A. Does the document provide a comprehensive description
of the POTW’s IU sampling practices including standard
procedures for sample collection, preservation, handling,
and storage?
B. Does the document clearly state that all sampling and
analyses performed by the POTW, or its designated
representatives (e.g., contract labs), will conform to the
requirements of 40 CFR Part 136?
C. If the POTW will utilize a contract laboratory for any
sampling or analyses, does the document clearly define
respective roles of the POTW and contractor?
D. Does the document provide a clear description of the
POTW’s inspection practices, including procedures for
preparation, entry, conduct, documentation, and follow-up
of IU inspections?
If YES, does it differentiate between initial, periodic, and
demand inspections?
PPD\WC15\WC15342.DOC
- 4 -
IMPLEMENTATION PROCEDURES EVALUATION CHECKLIST
continued
Requirement
YES
NO
N/A
Section Reference
E. Does the document contain complete and comprehensive
forms and documentation for the following items?
1. Sample collection forms?
2. Chain-of-custody forms?
3. Analytical report forms?
4. Inspection forms?
F. Does the document clearly establish the frequency with
which the POTW will perform inspections and sampling
for all SIUs?
If YES, does the frequency satisfy DEQ requirements for
a minimum of one documented annual inspection and two
sampling visits for all regulated pollutants at each SIU?
G. Does the document clearly identify the staff positions
responsible for all phases of the POTW’s sampling and
inspection program, including the specific responsibilities
of contract labs?
H. Does the document identify the sampling, analytical, and
inspection equipment, including the equipment to be used
by contract labs, for use in its sampling and inspection
program?
VII. Investigation of IU Noncompliance, Including
Evidence Gathering Procedures [40 CFR Part
403.8(f)(2)(vi)]
Adequate
Revision
Revision
Required
Recommended
A. Does the document clearly describe the POTW’s
procedures for review of all data (POTW and IU
generated) to identify all possible instances of IU
noncompliance?
B. Do the procedures described in the document for all
information gathering elements of the pretreatment
program (POTW and IU) ensure that such information
will be sufficient to produce evidence that would be
admissible in judicial proceedings?
VIII. Development and Implementation of an Enforcement
Response Plan (ERP) [40 CFR Part 403.8(f)(5)]
Adequate
Revision
Revision
Required
Recommended
A. Does the document include a copy of the POTW’s
Enforcement Response Plan?
If YES, complete the DEQ ERP Evaluation Checklist and
attach the checklist to this form.
If YES, is the ERP adequate?
PPD\WC15\WC15342.DOC
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