SITE INFORMATION AND CORRESPONDENCE

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City of Stockton - 7 - 13 December 2000 Pretreatment Compliance Audit 6. B.J.J Trucking is classified by the City as a non-categorical SIU. The facility washes the interior and exterior of truck tanks, which are used for transportation of corn syrup products. Onsite pretreatment facilities consist of four grease traps,.2-stage pH adjustment, an oil/water separator, and an activated sludge tank. The average total flow is 8,000 gpd. There are presently no local or federal effluent limits applied to this facility. Under the newly promulgated 40 CFR 442 regulations, this user may be classified as a CIU under the Transportation Equipment Cleaning Effluent Guidelines and subject to pretreatment standards for this category by 14 August 2003. There was documentation within the file indicating the City has made the IU aware of the new requirement. 7. Newark Sierra Paperboard Corporation is classified by the City as a CIU under 40 CFR 430.3 (t), Subpart E, Waste Paper. This industry manufactures recycled paperboard products. The process water contains fine cellulose fibers, clay particulates, and starch. Sanitary wastewater commingles with process water prior to pretreatment. On-site pretreatment consists of passing the wastewater through a dissolved air flotation unit prior to discharge to the sanitary sewer. The total average discharge flow is 800,000 gpd. The permit for this CIU does not expire until October 2002; however, the City must determine if the new 40 CFR 430 regulations apply to this user on or prior to 16 April 2001. No documentation within the file could be located to indicate that the N has been made aware of the new Federal requirement. File Organization State inspectors found the City's pretreatment files to be unorganized and some items appeared to be missing. However, by the end of the Audit, City Pretreatment staff and State inspectors were able to locate many of the missing items, noting that most were misfiled. Each ECO files correspondence differently and there appeared to be no overall continuity or consistency for filing by program staff. There was a lack of adequate correspondence documentation in a majority of the files. The continual decrease in pretreatment staffing levels and the continued increase in industrial users, most likely accounts for a majority of the file review problems encountered during this Audit. An example of a disorganized case file was that of Viktron. Folders, within the case file, labeled"Site Inspection, 1999 and 2000"contained chain of custody forms but no inspection reports. The site inspection reports were found in a folder labeled "Enforcement". Folders labeled "City Monitoring 1999 and 2000"were both empty. The results of the City compliance monitoring were summarized on tables with no supporting documentation within the "Enforcement" folder. Recommendation: It is important for a pretreatment program to maintain an efficient and thorough filing, documentation, and tracking system. The City should develop consistent documentation and file organization for the ECOs. All permits, inspections,formal and informal correspondence, monitoring data, and enforcement actions should be included within the files. The files should clearly document all inspections, industrial user violations, enforcement actions by the City, and subsequent compliance by the IU.