Wastewater Treatment Plant Compliance. Strategies for Surviving an NPDES Permit Inspection (National Pollutant Discharge Elimination System)

Transcription

1 Wastewater Treatment Plant Compliance Strategies for Surviving an NPDES Permit Inspection (National Pollutant Discharge Elimination System) Plus some general info about permits & reporting Eric Dunlavey Wastewater Compliance Supervisor San Jose Santa Clara Regional Wastewater Facility

2 Step One Know your Permit Know your Facility Know what your inspector wants

3 Know your permit(s) Nov 2014 to Feb 2019 Issued in 1995

4 NPDES Permit Outline NPDES Permit (pp. 1 14) I. Facility Info II. Findings III. Discharge Prohibitions IV. Effluent Limitations V. Receiving Water Limitations VI. Provisions VII. Compliance Determination Attachment A Definitions Attachment B/C Facility Map / Flow Schematic * Attachment D Federal Standard Provisions Attachment E Monitoring & Reporting Program (MRP) Attachment F Fact Sheet * Attachment G Standard Provisions (Bay Area) Attachment H Pretreatment Program Provisions * Unique to your facility

5 NPDES Permit: Things you must do 1. Keep Records (Attachments D & G) 2. Meet Effluent Limitations (Permit & MRP/Attachment E) Requirements to continuously monitor or sample: Turbidity, Chlorine, Bacteria, Dissolved Oxygen, ph 3. Report spills (Discharge prohibitions) (Permit & Attachment G) 2 hour reporting of sewage spills

6 NPDES Permit: Records (Standard Provisions, Attachments D & G) 1. Analytical Information MDLs, MLs, Reporting Levels, etc. 2. Flow Total daily, Max, Min, & Average daily for each month 3. Process Solids Volume from each collection unit grit, skimmings, biosolids 4. Disinfection Process Bacteriological Analyses flow rate, statistical parameters Chlorination Process Cl2 residual, Cl2 dose, Dechlor dose 5. Bypasses ID of process bypassed, dates and times, total volume, description of cause and corrective action 6. Overflows Chronological log of overflows, 24 hour reporting (2 hour per State order) Laboratory NoVax DCS DCS Ops Logs Ops Logs

7 Receiving Water Floating & suspended material Discoloration & turbidity Odor Beneficial use Hydrographic condition: time, tide, weather Temp & 5 day precipitation Wastewater Effluent Floating & Suspended material, Odor Land Retention or Disposal Area Freeboard of dykes, evidence of leaching, Odor, Waterfowl

8 Raw Sewage Floating & suspended material Discoloration & turbidity Odor

9 NPDES Section IV. Table 4 A. Conventional and Non Conventional Pollutants CBOD, TSS, Oil & Grease, ph, Chlorine Residual, Turbidity, Total Ammonia continuous, weekly, monthly B. Effluent limitations for Toxic Pollutants Copper, Nickel, Cyanide, Dioxin, Heptachlor, Tributyltin, Indeno (1,2,3 CD) Pyrene monthly, quarterly, or semi annual C. Dioxin semi annual D. Whole Effluent Toxicity 1. Acute quarterly 2. Chronic monthly

10 NPDES Section III and Attachment G A. Discharge of treated wastewater at a location or in a manner different that as permitted. B. Bypass of untreated or partially treated wastewater (blending can be allowed but must be reported.) C. Influent flow shall not exceed XX MGD average D. Sanitary Sewer Overflows are prohibited Report Spills Quickly!

11 Average Daily Max Turbidity 2 NTU 5 Total Coliform 2.2 (7 Day median) 23 (no more than one sample / 30 days)* 240 (ever)* Dissolved Oxygen 1.0 Dissolved Sulfide 0.1 * (California Health Laws Related to Recycled Water The Purple Book June 2001 page 46: Disinfected tertiary recycled water

12 Know Your Facility Effluent Sample Point: EFF 001 AKA: LER Influent Sample Point: INF 001 AKA: EPIC Secondary Treatment (Formerly Nitrification) What is the treatment train? (see Attachment F)

13 Know Your Facility Weir Bridge & SO2 Building: DO, ph, Chlorine NPDES Recycled Water EFF 001 (LER): Enterococcus by grab Filter Building Annex: Chlorine, Turbidity FE Sampler Diversion Shack: Turbidity, Chlorine RS Sampler Midpoint Shack: Turbidity, Chlorine Total Coliform by grab TPS: Turbidity, Chlorine Total Coliform by grab i.e.: Where are the regulatory sampling points? (see Attachment E)

14 THE CALL (your worst nightmare) Get Ready: (It s going to happen) Coming out to inspect next week. Have a nice day. How long will you be here? Anything you want to focus on? Do you have a checklist?

15 Have a Plan You before Do this now: Get the inspection checklist, if you can Review last inspection results Send an alert to all your people Get your documents ready Perform a pre inspection A Photo Safari Schedule a War Room meeting of facility staff Inspection Day: Reserve a study room The Think Tank Have subject experts standing by Plan a facility tour vehicle + senior operator Plant manager standing by for debrief in afternoon After inspection: Thank everyone for the help Correct anything noted in the inspection

16 Know what your inspector wants: The Checklist

17 Know what your inspector wants: The Last Inspection

18 Get People Ready: alert!!

19 Get your Stuff Together: The Documents Folder Electronic Folder Old School: pile of documents Do not be scrambling for documents during inspection!

20 No expired operators on duty! Lab Cert up to date!

21 Contingency Plan (Attachment G, Section I.C.1) Spill Prevention Plan (or SWPPP) (Attachment G, Section I.C.2) Tip: Inspectors like to look at wet weather prep procedures. Review & update these reports each year!

22 Spill Prevention Control & Countermeasures (SPCC) Plan (40 CFR Part 112 Oil Pollution Prevention) Reviewed & updated by registered engineer every 5 years.

23 Wastewater Facilities Status Report (Attachment G, Section D.2.) Discharger shall regularly review, revise, & update to ensure all facilities are adequately staffed, supervised, financed, operated, maintained, repaired &, upgraded Org Charts Operating Budgets CIP Summary Process Diagrams

24 A Tip Use your Annual SMR Report as a Wastewater Facilities Status Report Annual SMR Report Table of Contents

25 SOPs Electronic Library Old fashioned O&M Manual Are SOPs current? Do they get updated?

26 Incident Reports (electronic library) A good inspector will pick an incident then drill down!

27 Typical Incident Report Inspector Questions: Was a work order submitted? Did the part arrive? Was the problem corrected? Was additional training needed? Correction to SOP needed?

28 CMMS & Work Orders Work Order Did it get fixed?

29 Perform a Pre-Inspection i.e: Photo Safari send result via

30 Have a War Room Meeting Engineer Lab Operations Managers 1. Review last inspection. 2. Go over inspection check list item by item. Instrument Techs 3. Review pre inspection results. 4. Make sure each section has someone available during inspection.

31 Inspection Day Meet & greet Plant Manager, Chief Plant Operator, etc. Set up a study room for the day Have people standing by for the plant tour. Networked laptop Pile of documents Coffee

32 Facility Tour: Pre-Tour stop at the lab Lab Supervisor Chemist Inspector will verify random data entries in the SMR against lab records. Make sure a lab person is standing by.

33 Tour Stop 1: The influent Raw Sewage Sampler Raw Sewage Wet Well Bar Screens Grit Separators Do not go out alone! Have a senior operator accompany.

34 Tour Stop 2: Primary Primary Clarifiers Scum Separators

35 Tour Stop 3: Secondary Secondary Clarifiers Mixed Liquor Channels Check for flocs & other floating material Aeration Tanks

36 Tour Stop 4: Final Effluent Sampler Composite Sampler: Flow Proportioned, C Chlorine Analyzer & Logs Grab sample spigot free flowing

37 Tour Final Stop: Outfall Population 1,400,000 BOD (mg/l) 3 TSS (mg/l) 1.6 NH 3 (mg/l) 0.7 Diss. Oxygen (mg/l) > 5.5

38 The thank you

39 Have a Plan You before Do this now: Get the inspection checklist, if you can Review last inspection results Send an alert to all your people Get your documents ready Perform a pre inspection A Photo Safari Schedule a War Room meeting of facility staff Inspection Day: Reserve a study room The Think Tank Have subject experts standing by Plan a facility tour vehicle + senior operator Plant manager standing by for debrief in afternoon After inspection: Thank everyone for the help Correct anything noted in the inspection You After

40 Wastewater Treatment Plant Compliance Strategies for Surviving an NPDES Permit Inspection Eric Dunlavey Wastewater Compliance Supervisor San Jose Santa Clara Regional Wastewater Facility