j Water Utility Authority

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1 A Albuquerque Bernalillo County j Water Utility Authority PO Box 568 Albuquerque, NM FEDERAL EXPRESS Chair Art De La Cruz Commissioner, District 2 Vice Chair Rey Garduho Councilor, District 6 Richard J. Berry Mayor Trudy E. Jones C ty of Albuquerque Councilor, Distnct 8 Debbie O'Malley Commissioner, District 1 Ken Sanchez Councilor, District 1 Maggie Hart Stebbins Commissioner, District 3 Ex-Officio Member Pablo R. Rael Village of Los Ranchos Board Trustee Executive Director Mark S. Sanchez Website www abcwua org Ms. Hannah Branning Environmental Specialist NPDES Compliance Section (6EN-WC) 1445 Ross Avenue, Suite 1200 Dallas, TX SUBJECT: NPDES Permit No. NM Submittals to Meet Permit Conditions Dear Ms. Branning: The subject permit, effective October 1, 2012, contained permit conditions requiring submittal of policy, plans, ordinances, and program descriptions within one (1) year or 12 months of the effective date of the permit. In addition, the permit requires certification of the submittals. Requirements are presented below, along with the Albuquerque Bernalillo County Water Utility Authority (Water Authority) response to each requirement. Part I REQUIREMENTS FOR NPDES PERMITS (D) "The permittee shall institute a program within 12 months of the effective date of the permit (or continue an existing one) directed towards optimizing the efficiency and extending the useful life of the facility. The permittee shall consider the following items in the program: a The influent loading, flow, and design capacity; b. The effluent quality and plant performance; c. The age and expected life of the wastewater treatment facility's equipment; d Bypasses and overflows of the tributary sewerage system and treatment works; e. New developments at the facility; f. Operator certification and training plans and status; g The financial status of the facility; h Preventative maintenance programs and equipment conditions and; i An overall evaluation of conditions at the facility". The Pollution Prevention Program for POTW document is submitted to fulfill this requirement.

2 Page 2 Part II OTHER CONDITIONS (F): CAPACITY, MANAGEMENT OPERATIONS AND MAINTENANCE (CMOM) PLAN WITH EMPHASIS ON THE FATS, OIL, AND GREASE (FOG) POLICY F. CAPACITY, MANAGEMENT OPERATIONS AND MAINTENANCE (CMOM) PLAN WITH EMPHASIS ON THE FATS, OIL, AND GREASE (FOG) POLICY: "The facility shall within one (1) year from the permit effective date develop a CMOM plan with emphasis on the FOG policy. The goal of this plan is to reduce impacts on the sewer system caused by FOG. The FOG Policy will be a re-evaluation of the existing FOG Sewer Use and Wastewater Control Ordinance (SCO). The goal of the FOG Policy will be to reduce Sanitary Sewer Overflows (SSOs). The FOG Policy may address such items as an inventory of repeat Food Service Establishments (FSE) sources of SSOs, routine grease trap inspection programs at FSE with increased frequencies at repeat FOG SSO FSE's. Additional elements of the FOG Policy may be sewer line inspections, such as video recording and required sewer line cleaning activities if warranted at repeat sites. Inspections may include determination that a suitable sized grease trap is in place for the FSE it treats. The FOG Policy will be sent to both EPA and NMED for review, but will automatically be deemed approved if no action is received from the EPA and/or NMED, sixty (60) days after receipt. The FOG Policy will be part of the NPDES permit and become effective either thirty (30) days after EPA and/or NMED approval; or ninety (90) days after submission to EPA and NMED, whichever is earlier." In response to these requirements, the Water Authority submits the following documents for EPA and/or NMED review and approval: 1. Albuquerque Bernalillo County Water Utility Authority, Fats, Oils and Grease Policy, September CMOM Plan and Annual Report FY2013, Albuquerque Bernalillo County Water Utility Authority,. Appendix C of Part II, Contributing Industries and Pretreatment Requirements Appendix C of Part II, Contributing Industries and Pretreatment Requirements: "1. The permittee shall operate an industrial pretreatment program in accordance with Section 402(b)(8) of the Clean Water Act, the General Pretreatment Regulations (40 CFR Part 403) and the approved POTW pretreatment program submitted by the permittee. The pretreatment program was approved on September 21, 1985 and modified on March 24, The Sewer Use Ordinance and the Pretreatment Program have not been modified to come into compliance with the current 40 CFR Part 403 regulations. The

3 Page 3 permittee shall,submit all necessary proposed modifications to the EPA within 12 months of the effective date of this permit. The POTW pretreatment program is hereby incorporated by reference and shall be implemented in a manner consistent with the following requirements: The permittee shall establish and enforce specific limits that implement the provisions of 40 CFR 403.5(a) and (b), as required by 40 CFR Part 403.5(c). POTWs may develop Best Management Practices (BMPs) to implement paragraphs 40 CFR (c)(1) and (c)(2). Such BMPs shall be considered local limits and Pretreatment Standards. Each POTW with an approved pretreatment program shall continue to develop these limits as necessary and effectively enforce such limits. The permittee shall, within sixty (60) days of the effective date of this permit, (1) submit a WRITTEN CERTIFICATION that a technical evaluation has been demonstrated that the existing technically based local limits (TBLL) are based on current state water quality standards and are adequate to prevent pass through of pollutants, inhibition of or interference with the treatment facility, worker health and safety problems, and sludge contamination, OR (2) submit a WRITTEN NOTIFICATION that a technical evaluation revising the current TBLL and a draft sewer use ordinance which incorporates such revisions will be submitted within 12 months of the effective date of this permit." In response to these requirements, the Water Authority submitted written notification on November 20, 2012 that a technical evaluation revising the current TBLL and a draft sewer use ordinance would be submitted within 12 months of the effective date of the permit. The Water Authority submits the following documents for EPA and/or NMED review and approval: 3. Albuquerque Bernalillo County Water Utility Authority, SECTION 3. SEWER USE AND WASTEWATER CONTROL ORDINANCE, September Albuquerque Bernalillo County Water Utility Authority, INDUSTRIAL PRETREATMENT PROGRAM ENFORCEMENT RESPONSE PLAN, Albuquerque Bernalillo County Water Utility Authority,. 5. INDUSTRIAL PRETREATMENT PROGRAM LOCAL LIMITS TECHNICAL ANALYSIS REPORT 2013 UPDATE, Albuquerque Bernalillo County Water Utility, September Response to Comments, Sewer Use and Wastewater Control Ordinance, Technically Based Local Limits, Fats, Oils and Grease Policy, and Enforcement Response Plan, September 2013

4 Page 4 As per Appendix C of Part II, Contributing Industries and Pretreatment Requirements, 1(g): "The approved program shall not be modified by the permittee without the prior approval of the Agency." Upon receipt of approval of the draft documents listed above, the documents will be introduced for adoption by the Water Authority Governing Board. Part III STANDARD CONDITIONS FOR NPDES PERMIT (D) (11) (b) and (c) Part Ill STANDARD CONDITIONS FOR NPDES PERMIT (D) (11) (b) : " b. ALL REPORTS required by the permit and other information requested by the Director shall be signed by a person described above or by a duly authorized representative of that person." Part III STANDARD CONDITIONS FOR NPDES PERMIT (D) (11) (c): "c. CERTIFICATION Any person signing a document under this section shall make the following certification: I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility affine and imprisonment for knowing violations." The signed certification is submitted as an attachment to this document. If there are any questions or comments regarding these submittals, please contact me at (505) Respectfully submitted, J M. Stomp Ill, P.E. C 'e Operations Officer cc: Bruce Yurdin, NMED/SWQB Program Manager Eddie Paul Torres Sr, Governor, Pueblo of Isleta Ramona Montoya, Environment Division Manager, Pueblo of Isleta

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