APPENDIX A:  ENFORCEMENT RESPONSE GUIDE
DESCRIPTION OF TERMS
   Terms and abbreviations used in the Enforcement Response Guide are defined below.
 
AO
-  Administrative Order
Civil Action
-  Action taken toward civil litigation against the industrial user seeking equitable relief, monetary penalties and actual damages.
Criminal Investigation
-  Investigation in the pursuit of punitive measures against an individual and/or organization through a court of law.
Fine
-  Monetary penalty assessed by City officials.  Fines should be assessed by the pre-treatment coordinator or the POTW's Superintendent.
I
-  Inspector.
IU
-  Industrial User.
Meeting
-  Informal compliance meeting with the IU to resolve recurring noncompliance.
NOV
Notice of Violation.
PC
Pretreatment Coordinator/City Engineer
CO
-  Chief Operator.
SV
-  Significant Violation.
Show Cause
-  Formal meeting requiring the IU to appear and demonstrate why the city should not take a proposed enforcement action against it.  The meeting may also serve as a forum to discuss corrective actions and compliance schedules.
(-)
-  Indicates one or more of the responses noted are recommended depending on the severity of the case.
 
ENFORCEMENT RESPONSE GUIDE
 
DISCHARGE LIMIT VIOLATION
 
MONITORING AND REPORTING VIOLATIONS
 
 
OTHER PERMIT VIOLATIONS
 
VIOLATIONS DETECTED DURING SITE VISITS
 
TIME FRAME FOR RESPONSES
   (A)   All violations will be identified and documented within five (5) days of receiving compliance information.
   (B)   Initial enforcement responses [involving contact with industrial user and requesting information on corrective or preventive action(s)] will occur within fifteen (15) days of violation detection.
   (C)   Follow up actions for continuing or reoccurring violations will be taken within sixty (60) days of the initial enforcement response.  For all continuing violations, the response will include a compliance schedule.
   (D)   Violations which threaten health, property or environmental quality are considered emergencies and will receive immediate responses such as halting the discharge or terminating service.
   (E)   All violations meeting the criteria for significant noncompliance will be addressed with an enforceable order within thirty (30) days of the identification of significant noncompliance.