Page 134 - Yucaipa Valley Water District - Board Workshop

Workshop Memorandum 18-251

Date: November 13, 2018

From: John Wrobel, Public Works Manager

Subject: Ratification of the Issuance of a Class II Non-Significant Industrial User Discharge
Permit to Skat-Trak Performance Products - Permit No. CP-003-03

Publicly owned treatment works (POTWs) collect waste from homes, commercial buildings, and
industrial facilities and transport the water carrying waste via a series of pipes, known as a sewer
collection system to a sewer treatment plant. Here, the POTW is responsible for separating the
waste from the water.

Generally, POTWs are designed to treat waste in water from typical domestic uses. However,
POTWs also receive waste from industrial (non-domestic) users. Industrial wastewater often
includes by-product chemicals from production and manufacturing processes that can contain
chemicals such as copper, lead, nickel, and other heavy metals. Because certain wastes can
interfere with the biological or filtration treatment processes, these wastes must be removed before
they are discharged into a sewer collection system.

The removal process is known as "pretreatment" and is enforced by the General Pretreatment
Regulations at 40 CFR 403.1 et seq. which establish the responsibilities of government agencies
and industries to implement practices to control industrial wastes that may pass through or interfere
with publicly owned treatment works (POTWs) or contaminate sewage sludge.

In 1978, U.S. EPA promulgated extensive regulations requiring many POTWs to develop and
implement local pretreatment programs. U.S. EPA delegated the responsibility to oversee these
pretreatment programs to the State Water Board and Regional Water Boards in 1989. As a result,
the State and Regional Water Quality Control Boards are responsible for the review and approval of
POTW pretreatment programs. The discharge permits for POTWs spell out the pretreatment
program monitoring and reporting requirements.

The Regional Water Board's pretreatment program includes pretreatment compliance audits,
inspections, annual and semiannual report reviews, program modifications, and enforcement
activities. Pretreatment compliance inspections verify the compliance status of POTWs, focusing on
the POTW's own compliance monitoring and enforcement activities. Pretreatment compliance audits
involve a comprehensive review of all elements of a POTW's pretreatment program. Audits take
place every five years. Inspections usually occur every year, except when an audit is scheduled.

The attached pretreatment permit outlines the pollutant limitations for the industrial wastewater to be
discharged from the Skat-Trak Performance Products facility located at 654 Avenue. “K”.

Yucaipa Valley Water District - November 13, 2018 - Page 134 of 166