CHAPTER 3 Audit Checklist Instructions
A.1.d. Has the CA amended its pretreatment program to include the following components
required under the 2005 amendments to the General Pretreatment Regulations: slug
control requirements in control mechanisms [40 CFR 403.8(f)(1)(iii)(B)(6)]; notification
requirements to include changes that might affect the potential for a slug discharge [40
CFR 403.8(f)(2)(vi)]; revised SNC definition [40 CFR 403.8(f)(2)(viii)]; clarification that SIU
reports must include any applicable BMP compliance information [40 CFR 40.12(b); (e),
(h)]; SIU control mechanisms must contain any BMPs required by a Pretreatment
Standard, local limits, state, or local law [40 CFR 403.8(f)(1)(iii)(B)(3)]; record-keeping
requirements for BMPs [40 CFR 403.12(o)]; clarification that CAs that perform sampling
for SIUs must perform any required repeat sampling and analysis within 30 days of
becoming aware of a violation [40 CFR 403.12(g)(2)]; modifications to the sampling
requirements [40 CFR 403.12(g)]; and requirement to report all monitoring results [40 CFR
403.12(g)]. If not, when?
A.1.e. Has the CA adopted or does the CA plan to adopt any of the optional measures provided by
the 2005 amendments to the General Pretreatment Regulations? If yes, check which ones.
(Issuance of monitoring waivers for pollutants that are not present [40 CFR 403.8(f)(2)(v)
and 403.12(e)(2)]; issuance of general control mechanisms to regulate multiple industrial
dischargers with similar wastes [40 CFR 403.8(f)(1)(iii)]; using BMPs as an alternative to
numeric limits; authority to implement alternative sampling [40 CFR 403.3(e), 403.5(c)(4),
403.12(b), (e), and (h)], reporting, and inspections frequencies for NSCIUs [40 CFR
403.3(v)(2), 403.8(f)(2)(v)(B), 403.8(f)(6), 403.12(e)(i), 403.12(g), (i), and (q)]; authority to
implement alternative sampling, reporting, inspections frequencies for middle-tier CIUs [40
CFR 403.8(f)(2)(v)(C), 403.12(e)(3), and 403.12(i)]; authority to implement equivalent
concentration limits for flow-based standards [40 CFR 403.6(c)(6)]; and authority to
implement equivalent mass limits for concentration-based standards [40 CFR 403.6(c)(5)].)
A.2.a. Are there any planned changes to the POTW’s treatment plant(s)? If yes, describe.
A.2.b. Are these changes to the treatment plant(s) due to pretreatment issues? If yes, what were
the issues?
PURPOSE: The CA is required to notify the AA of any substantial modifications it intends to
make in its pretreatment program. Substantial modifications should not be made without approval
by the AA. Note, however, that the changes to the pretreatment program due to the 2005 revisions
3-2 February 2010