FW: Evergreen Interlocal Agreement and PretreatmentJane:
We are getting our ducks in row for the possibility of opening
negotiations with Evergreen this July. Rebecca has made this suggestion
and we are keeping it handy.
Jim H
From: Rebecca Bodnar
Sent: Friday, May 07, 2010 1:39 PM
To: Jim Hansz
Subject: FW: Evergreen Interlocal Agreement and Pretreatment
Jim,
When the Evergreen Interlocal Agreement is evaluated and renegotiated,
language from our NPDES permit (No. MT0021938, Section E "Pretreatment
Requirements") will need to be included per the MT Water Quality Act and
the Federal Water Pollution Control Act. This language includes:
- Right of Industrial user inspections
- Slug control plans
- Right to investigate instances of non-compliance
- Establishment and enforcement of specific local limits and
Best Management Practices.
(local limits to include TSS, BOD, Phosphorus limits, Ammonia limits,
possible Nitrogen limits and all heavy metal limits)
Additionally, trucked and hauled waste haulers are subject to
Pretreatment Standards and must be individually permitted by the POTW to
prevent illegal discharge by industrial users. Particularly:
- "Identification of the specific locations, if any, designated
by the Permittee for receipt (discharge) of trucked or hauled waste"
- "Information required by the EPA or the Department on the
discharge to the POTW from trucked or hauled waste". This includes user
manifests, and logs of specific pollutants (ie microbiological septage
treatment).
- Specifically, no user shall discharge any waste that may
cause Pass Through or Interference with the proper operation of the
POTW. Trucked and hauled waste haulers are prohibited from introducing
the list of pollutants under Section E: 5 (see attached).
- The City of Kalispell shall provide adequate staff, equip
and support capabilities to carry out all elements of the pretreatment
program (Section E: 1: g). This would include sampling for baseline
data for domestically hauled waste nutrient concentrations.
The City of Kalispell, as the NPDES permit holder, is held liable for
failure to improperly develop and enforce such standards according to
our permit, Section E: 8.
Of course, if you have any additional questions, or need more specific
details, please feel free to call or email.
Cheers! Have a great weekend,
Rebecca
Rebecca J. Bodnar
Industrial Pretreatment Program Coordinator
Kalispell Municipal Environmental Laboratory
PO Box 1997
2001 Airport Rd
Kalispell, MT 59901
(406) 758-7801