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..measured value of a pollutant in the residual sewage sludge integrates the impact <br />- of a discharge of a pollutant into the wastewater system over time. An industrial <br />discharge would cause sludge contamination if the mass of the pollutant discharged <br />over a period of time was sufficient to result in the concentration of the pollutant in <br />the sludge following digestion exceeding the standards in 40 CFR Part 503.13 <br />Table 3. The correlation between industry discharge data and sludge quality data <br />will have to be present before an enforcement action is initiated against an industry <br />for sludge contamination. <br />.Comment 10: !s 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-monitoring violations because of the other options now available for quick <br />reporting, such as fax and electronic mail. The telephone will remain an acceptable <br />means of reporting. <br />Comment 11: The Enforcement Response Guide appears to allow the <br />discharge of Hazardous Waste into the POTW. Shouldn't Hazardous Waste be <br />prohibited from discharge? <br />Finding: The discharge of a material which would be classified as a <br />hazardous waste is not necessarily prohibited from discharge into the wastewater <br />system.. Federal regulations allow the discharge of hazardous waste into a sewer <br />containing domestic waste, under a provision in the solid- waste regulations known <br />as the domestic sewage exclusion (40 CFR Part 261.4(a)(1)(ii)). Section 6.536 of <br />the Eugene Code, 1971 requires that any .person who desires to dispose of any <br />.hazardous waste in the wastewater system first obtain prior permission from the City <br />for the discharge, and comply with all EPA-required reporting following the <br />discharge. In some limited situations a material that is classified as a hazardous <br />waste 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 />Wastewater Discharge Permit. <br />Comment 12: Concerning the fines for Mobile Waste Haulers. A hauler <br />.found to be noncompliant should be turned away until they are compliant and not <br />just fined. This would lessen administrative time in handling paperwork. Fining and <br />allowing the hauler to continue using the system does not work. <br />Finding: The City believes that the issuance of an administrative civil <br />penalty is an appropriate enforcement response following minor violations of the <br />pretreatment program regulations. A mobile waste hauler's permit can be revoked <br />following repeated serious violations, or for failure to pay user charges. <br />Comment 13: Comment on the proposed new penalty of $5000 for a Mobile <br />Administrative Order - 5 ~o~22i9~ <br />