SITE INFORMATION AND CORRESPONDENCE

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City of Stockton - 9 - 13 December 2000 Pretreatment Compliance Audit Review of the cited files indicates that site visits for compliance monitoring(or sampling) are occurring with significant frequency. In the case of the Viktron file, compliance effluent sampling visits occurred on a monthly and sometimes weekly basis over 1999 and 2000. However, other than having a chain of custody form and sample results for each visit, there was no documentation of what was observed at the site during the sampling visit. Without some form of documentation of the sampling, the site visit is not considered a site inspection and serves as a poor basis for determining compliance/noncompliance. Recommendation: Pretreatment Program staff should work together to develop a consistent inspection report formai. Inspection reports should be peer reviewed for consistency with respect to the developed format. Inspection reports should be filed in appropriate labeled folders in the case file. Additional documentation is needed for sampling inspections to clarify when split samples are collected and analyzed, site conditions at the time of sample collection, or other information pertinent to determination of compliance. Information/Fact Sheet Review of the various permits found that other than a lead permit authorization page, there were no associated information summaries or fact sheets within the industrial user files. The required information for some, but not all, of the files reviewed were found within the permit and file folders. It would be useful to City staff, the permitted IU, inspectors, and outside reviewers, to have supplemental information summarized in a fact sheet attached at the front of each permit. Typical fact sheets may include the following: (1) Industry name, site location, mailing address, contact person, phone and fax numbers; (2) Type of industry and dates of seasonal operation, (3)Dates operation began and changes were instituted, (4) Applicable categorical pretreatment standards (from 40 CFR Parts 403-471) including existing or new source and subcategory, process and total flows, pretreatment mechanisms in place, applicable combined wastestream formulas, (5) monitoring and sampling frequency and location, and any other information deemed important by the City Technical Services Supervisor. An example of a file missing important information is that of the Newark Sierra Paperboard Corporation. This facility is classified by the City as an existing paperboard industry. The categorical listing is found under 40 CFR 430.3 (t), Subpart E, Waste Paper. As such, the City must determine if new regulations under 40 CFR will require the issuance of a new permit prior to 16 April 2001 whereas the existing permit does not expire until October 2002. Additionally, there is no justification within the permit that explains how this facility was classified. Under the existing category, the industry is required to have production-based limits; however, there is no information within the permit to state how this was determined. The use of an information sheet with this permit would allow the ECO, outside reviewers, and the permitted IUs to be aware of special conditions that apply to this permit.