Permitting, Reporting, and Recordkeeping
All coating facilities that discharge process wastewater to a POTW are subject to some monitoring, reporting, and recordkeeping requirements. Facilities that are subject to categorical pretreatment standards have special requirements. In all cases, contact your Control Authority to determine your specific requirements.
Typical requirements are summarized in this section:
Permit
Industrial users are required to obtain a permit before discharging process wastewater to a POTW. The permits are issued by the POTW itself and typically must be renewed every three to five years. The permits will usually contain discharge limitations and standards, and monitoring, reporting and recording requirements. Typically, the permits incorporate any requirements of categorical standards, if they apply to the facility.
Baseline Monitoring Reports
All industrial users subject to Categorical Pretreatment Standards must submit a baseline monitoring report (BMR) to the Control Authority. The purpose of the BMR is to provide information to the Control Authority to document the industrial user's current compliance status with a Categorical Pretreatment Standard. The Control Authority is defined as the POTW if it has an approved pretreatment program, otherwise the BMR will be submitted to the State (if the State has an approved State Pretreatment Program) or to the EPA Region.
Coating facilities not subject to Categorical Pretreatment Standards do not have to submit a BMR.
Additional information on Baseline Monitoring Reports.
Report on Compliance
Within 90 days after the compliance date for the Coil Coating, Electroplating, or Metal Finishing Pretreatment Standards or in the case of a New Source following commencement of the introduction of wastewater into the POTW, any industrial user subject to the Standards must submit to their Control Authority a "report on compliance" that states whether or not applicable pretreatment standards are being met on a consistent basis. The report must indicate:
- Chemical name and concentration of all regulated pollutants in the facility's regulated process wastestreams
- Average and maximum daily flows of the regulated streams
- A statement of whether compliance is consistently being achieved, and if not,
- What additional operation and maintenance and/or pretreatment is necessary to achieve compliance.
See section 40 CFR 403.12(d) of the General Pretreatment Regulations.
Periodic Reports on Continued Compliance
Unless required more frequently by the Control Authority, all industrial users subject to Categorical Pretreatment Standards and significant industrial users must submit a biannual "periodic compliance report" during the months of June and December. The report must include:
- Chemical name and concentration of all regulated pollutants in the facility's regulated process wastestreams
- Average and maximum daily flows of the regulated streams
- Methods used to sample and analyze the data
- A certification that these methods conformed to those methods outlined in the regulations.
Sampling and analysis procedures are found in 40 CFR Part 136.
See section 40 CFR 403.12(e) of the General Pretreatment Regulations.
Notice of Slug Loading
All industrial users are required to notify the POTW (#12) immediately of any slug loading (i.e., discharge of concentrated waste) of any pollutant, including organic and inorganic wastes, is released to the POTW system at a flow rate and/or pollutant concentration which will cause interference with the POTW. See section 40 CFR 403.12(f) of the General Pretreatment Regulations.
Recordkeeping Requirements
Any industrial user subject to the reporting requirements of the General Pretreatment Regulations must maintain records of all information resulting from any monitoring activities required by 403.12 for a minimum of three years. These records must be available for inspection and copying by the Control Authority. See section 40 CFR 403.12(n) of the General Pretreatment Regulations.
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