Baseline monitoring reports 1

[koshyeng]

Does an user required to have baseline monitoring report even though the site doesn't have applicable pretreatment standards (falls under specific industrial categeory which has no applicable pretreatment standards)

 

[bimr]

Any industrial user that is subject to categorical pretreatment standards found in 40 CFR 400-499 must submit a baseline monitoring report (BMR) to the control authority (POTW, state, or EPA). The purpose of the BMR is to provide information to the control authority to document the industrial user's current compliance status with a categorical pretreatment standard.

So if you are not subject to categorical pretreatment standards, there answer is no.

 

[koshyeng]

Thanks for your response bimr.

So if an industry fall under a specific industrial category which has no pretreatment standards, you don't need to have a baseline monitoring report to the control authority (POTW). Is this right?

Please make me understand what is a regulated process (EPA)?

 

[bimr]

If an industry is not listed as a specific industrial category, you don't need to have a baseline monitoring report to the control authority (POTW).

A regulated process is one of the unit process of the particular categorical industry. For example, that would be the pharmaceutical manufacturing processes in the pharmaceutical categorical pretreatment standard. Regulated processes would not include other processes at the same site such as the sanitary waste and other manufacturing processes on the same site.

 

[koshyeng]

What if an industry is listed as a specific indutrial category and is exempted for categorical pretreatment standards in Appendix D of 40 CFR 403. Do they still require to have a Baseline Monitoring Report?

Appreciate your help.

 

[bimr]

Federal Categorical Standards apply to facilities engaged is some specific activities. Not all standards have pretreatment requirements, and standards may exempt certain subclasses.

If you are exempt, then you should not need to complete a Baseline Monitoring Report (BMR).

However, some Delegated Local Agency may require you to submit a BMR to certify that you are exempt as stated in the example below:

STATEMENT OF COMPLIANCE
This statement is to be made by a qualified environmental professional or )for the exempt category) by a responsible company official. I hereby certify that the EPA categorical pretreatment standards which apply to this company are being met on a consistent basis.

Yes______No______Exempt______

You should contact the Delegated Local Agency receiving the discharge if you are uncertain if you are covered under any of the standards.

 

[koshyeng]

Thank You very much bimr.