Wastewater Regulatory Inspections

Transcription

1 Wastewater Regulatory Inspections Preparing for Success Michael Cherniak, Woodard & Curran Inspections and the future.potential problems ahead. AWWA study indicates 50% of operators could retire in next 10 years Who will operate and maintain plants? What are the sources of future operators? How will these operators be adequately trained to operate more complex facilities? FYI the average operator is 50 yrs old. 4/19/07 (Active + Inactive) Age Bracket Total License Holders # of Licensee's Overall % 30 and younger % 14.5 % 34.9 % 35.0 % 10.8 % 1.4 % 0.2 % * This data only represents approx 76.3% of all license holders as of 4/19/ * 1

2 Treatment Plant Operator Age Comparison % 35.0% % 10.8% # of Licenses % 1.4% 0.2% 0 30 & Younger & Older Small System Operators Face the Need to Increase Knowledge and Skill Requirements Better understanding of microbiology and chemistry Skilled at electronics, relays, troubleshooting Public safety, security and permits Mathematics, data management SCADA and instrumentation comprehension Computer/software use Grammar, rules of composition better writing skills Types of Inspections? ComplianceEvaluations Sampling Bio-monitoring Pretreatment Reconnaissance 2

3 General Notations. State inspections may have advance notice. EPA inspections generally unannounced. Inspectors review records before arriving. Before Visit, Inspector Reviews. Discharge Monitoring Reports Recent Toxicity testing (WET) results Disinfection monitoring results Sludge Vector Attraction and Pathogen Monitoring records Annual reuse forms (if applicable) Groundwater monitoring records Before THEY Visit, WE should. Assure gate curb appeal. Roll up hoses, landscape, remove junk, debris, and spare parts. Assure that lab or test areas are clean and orderly. Address odor problems as best as possible. Assure that the perimeter is secure. 3

4 Are YOU impressed? Before THEY Visit, WE Should. Prepare a binder or binders with: A copy of the NPDES permit, 90 days of DMRs, Recent Whole Effluent Toxicity results, Most recent 503 biosolids report, Copies of analyses chain-of-custodies Copies of odor or nuisance complaints, Flow and/or process trend charts Upon Arrival. Inspectors present credentials. Plant manager or supervisor should meet and greet. Inform inspector of any safety hazards or relevant plant notes and let them go! 4

5 During the Inspection. The inspector will tour, perhaps take photos, collect samples, and may interview available staff. Plant staff should just do their jobs. Avoid accompanying the inspector. Let them be comfortable in their survey. Be available to assist if they ask! After the Inspection Meet the inspector to discuss the results before they leave the site. Clarify findings, take notes, be cordial and professional. If photos were taken, discuss them. If samples have been taken - split them. Use the opportunity to ask the inspector about any regulatory questions that you might have. If DEFICIENCES are noted.. A notice of potential violations may be sent to the permittee. Generally 10 days to respond with a plan of action may be lengthened. Within 60 days of an inspection, EPA will notify the permittee and state what actions need to be taken. 5

6 Responding to Deficiency Notices? Keep it simple and clear less is more. Stick to the items in question don t bring up tangential issues. Provide a proactive plan tell them what you are going to DO? HOW? and by WHEN. Be positive in tone avoid defensiveness. Review the response with key staff. Never argue with folks that buy paper by the ton and ink by the barrel. Recommended Preparation Focal Points 1. Is the site clean and secure? 2. Are sampling points labeled, representative and are samples collected and maintained at correct temperatures? Recommended Preparation Focal Points 3. Does the grit and screenings area appear to be well managed? 4. Does sample tubing on composite samplers need to be changed? 6

7 If it looks like it needs cleaning, just replace it Recommended Focus Points 5. Are all flow meters properly calibrated and tagged? 6. Are all on-line instruments (ph, turbidity, dissolved oxygen, etc) routinely (and properly) maintained and calibrated and documented as such? Be sure primary device is accurate 7

8 Recommended Focus Points 7. Is all critical equipment operational (headworks, blowers, filters, solids handling, generators)? 8. Process appearance should be good. There should be no excessive scum, foam, or objectionable odors. A picture is worth a thousand words Recommended Focus Points 9. Is the biological system being operated with a strategy? your pick! Just have one and back up it s existence with some kind of records. 10. Is the solids thickening / dewatering area clean? 11. Is the chlorine contact tank clean can you see the bottom? 8

9 That s more like it Recommended Focus Points 12. Do staff know HOW to properly collect samples? 13. Do you have properly prepared chain of custody documents? 14. Has the equipment in the laboratory been serviced / calibrated / tagged? 15. Are your lab bench sheets properly filled out and organized? Recommended Focus Points 16. Do you have a lab Quality Assurance Quality Control plan? Are you using it? 17. Are you maintaining good sludge records volumes, characteristics, disposal activities? 18. Is the disinfection process (particularly with chlorine) in proper operating condition all equipment functional, no leaks, clean. 9

10 Be careful when storing chemicals Recommended Focus Points 19. Are generators operable, maintained, and ready? 20. Do you have your plans in order? Risk Management Plan (RMP), Spill Prevention (SPCC), emergency action SOPs. Final Notes Preparation should be happening all the time within daily work activities. Staff should be trained about the inspection process. Manage a quality lab and data system! USA Bluebook Project DVD is a visual guide reference source. 10

11 Wastewater Regulatory Inspections A Visual Guide to High Performance Walk through of Tallahassee, FL WWTP. Approximate 80 minute guided tour. 15 sections. Very strong lab reviews. DVD contains interactive EPA NPDES Compliance Inspection Manual. Printable self-inspection checklist. Practice quiz based on the manual. Wastewater Regulatory Inspections A Visual Guide to High Performance DVD provides very nice visual aid to process training programs. Demo discs are available $395 from USA BlueBook No, I do not get royalties Thank you for having me! 11