,i <br /> ~'~I mea ured value of a pollutant in the residual sewage sludge integrates the impact <br /> of a ischarge of a pollutant into the wastewater system over time. An industrial <br /> disc arge would cause sludge contamination if the mass of the pollutant discharged <br /> over period of time was sufficient to result in the concentration of the pollutant in <br /> the Judge following digestion exceeding the standards in 40 CFR Part 503.13 <br /> Tabl 3. The correlation between industry discharge data and sludge quality data <br /> will h ve to be present before an enforcement action is initiated against an industry <br /> for sl dge contamination. <br /> Comment 10: Is the telephone still an acceptable means to perform a 24 <br /> hour notice of aself-monitoring violation. <br /> Finding: The word "telephone" is deleted from reporting requirements for <br /> self- onitoring violations because of the other options now available for quick <br /> repo ing, such as fax and electronic mail. The telephone will remain an acceptable <br /> mea s of reporting. <br /> Comment 11: The Enforcement Response Guide appears to allow the <br /> disc arge of Hazardous Waste into the POTW. Shouldn't Hazardous Waste be <br /> prohi ited from discharge? <br /> Finding: The discharge of a material which would be classified as a <br /> <br /> ' haza dous waste is not necessarily prohibited from discharge into the wastewater <br /> syst .Federal regulations allow the discharge of hazardous waste into a sewer <br /> ' cont fining domestic waste, under a provision in the solid waste regulations known <br /> as th domestic sewage exclusion (40 CFR Part 261.4(a)(1)(ii)). Section 6.536 of <br /> the ugene Code, 1971 requires that any person who desires to dispose of any <br /> haza dous waste in the wastewater system first obtain prior permission from the City <br /> for t e discharge, and comply with all EPA-required reporting following the <br /> disc arge. In some limited situations a material that is classified as a hazardous <br /> avast may be compatible with the wastewater system. The discharge would also <br /> have to comply with all other requirements of the Eugene Code, 1971 or a <br /> Was water Discharge Permit. <br /> Comment 12: Concerning the fines for Mobile Waste Haulers. A hauler <br /> foun to be noncompliant should be turned away until they are compliant and not <br /> just fi ed. This would lessen administrative time in handling paperwork. Fining and <br /> allo ng the hauler to continue using the system does not work. <br /> Finding: The City believes that the issuance of an administrative civil <br /> pena ty is an appropriate enforcement response following minor violations of the <br /> pretr atment program regulations. A mobile waste hauler's permit can be revoked <br /> folio ing repeated serious violations, or for failure to pay user charges. <br /> Comment 13: Comment on the proposed new penalty of $5000 for aMobile - <br /> Administrati a Order - 5 10/22!97 <br /> <br />