EPA NPDES inspectors conducted a pretreatment compliance inspection (PCI) at the Bozeman Wastewater Treatment Plant on September 8-9, 2014. Several deficiencies and associated corrective actions were noted. Among those deficiencies were the recurring failures to implement the City?s approved pretreatment program, summarized below. Many of these findings have been identified in previous PCIs and pretreatment audits as well as other communications with the City.
Failure to Identify and Locate All Possible IUs Subject to Pretreatment Program and to Characterize IUs? Waste
Failure to Prepare, Maintain, and Submit a List of SIUs
Inadequate Legal Authority
Failure to Update Local Limits
Failure to Enforce Local Limits
Failure to Control SIUs Through Permit, Order, or Similar Means
Failure to Operate Consistent with Respondent?s Legal Authority
Failure to Include All Required Elements in SIU Permits
Failure to Evaluate SIUs for the Need to Develop a Slug Plan or Other Slug Controls
Failure to Conduct Inspections with Sufficient Care to Produce Admissible Evidence
Failure to Sample SIUs at Least Annually
Failure to Conduct Sampling and Analyses Using Required Methods and Techniques
Failure to Create and Maintain Records
Failure to Enforce According to the Respondent?s Enforcement Response Plan
Failure to Develop and Implement Accurate SNC Procedure
Failure to Have Adequate Resources to Implement the Pretreatment Program
The Order requires the City to take several