Surviving an NPDES Permit Inspection. General info about permits, limits, & reporting

Transcription

1 Wastewater Treatment Plant Compliance Surviving an NPDES Permit Inspection General info about permits, limits, & reporting

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 Mercury & PCBs Watershed Permit Nutrient Watershed Permit

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

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

7 Know what your inspector wants The Call (your worst nightmare) 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?

8 Know what your inspector wants: The Checklist

9 Get People Ready The alert

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

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

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

13 Wastewater Facilities Status Report (Attachment G, Section D.2.) 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

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

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

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

17 CMMS & a typical Work Order Work Order Did it get fixed?

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

19 Check for House Keeping Pre-Inspection i.e: Photo Safari send result via

20 The 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.

21 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 Plant Manager & Compliance Team at the door Pile of documents Coffee

22 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.

23 Tour Stop 1- The influent

24 Tour Stop 2 - Raw Sewage Sampler

25 Tour Stop 3 - Primary

26 Tour Stop 4 - Secondary

27 Tour Stop 5 Final Effluent Sampler

28 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

29 The thank you

30 Wastewater Treatment Plant Compliance General Info about permits, limits, & reporting

31 Federal EPA California Water Resources Control Board San Francisco Bay Water Quality Control Board

32 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 Attachment I - Actions to meet WQ 90-5 (San Jose only)

33 1. Records (Attachments D & G) 2. Effluent Limitations (Permit & MRP/Attachment E) Requirements to continuously monitor or sample: Turbidity, Chlorine, Bacteria, Dissolved Oxygen, ph 3. Discharge prohibitions (Permit & Attachment G) 2-hour reporting of sewage spills

34 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

35 Receiving Water shall not cause 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

36 Raw Sewage Floating & suspended material Discoloration & turbidity Odor

37 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 - quarterly or semi annual C. Dioxin semi annual D. Whole Effluent Toxicity 1. Acute - quarterly 2. Chronic - monthly

38 Plus: Average monthly removal of CBOD and TSS must be at least 85% Enterococcus Bacteria shall not exceed 30-day geo-mean of 35 colonies Daily Grab sample

39 Monthly 2/year Quarterly All Analyzed in Lab from C-24 samples

40 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

41 Acute Toxicity: 90% Survival using most sensitive species Please don t kill me. Rainbow Trout Chronic Toxicity: 3-Sample Median of 1 Toxicity Unit (TUc) Please don t inhibit my reproduction. Ceriodaphnia

42 Enterococcus: 30 day geo-mean < 35 colonies Fecal Coliform: No Permit Limit But, WQO = 200 colonies/100 ml

43 FE SEA/SEB TFBW RS PE SS SEB FI NE

44 Effluent: EFF-001 AKA: LER Influent: INF-001 AKA: EPIC AKA: Raw Sewage

45 Weir Bridge & SO2 Building: DO, ph, Chlorine EFF-001 (LER): Enterococcus by grab FE Flow Filter Building Annex: Chlorine, Turbidity Diversion Shack: Turbidity, Chlorine Midpoint Shack: Turbidity, Chlorine Total Coliform by grab RS Flow TPS: Turbidity, Chlorine Total Coliform by grab

46 SO2 Building: Chlorine Filter Building Annex: Turbidity Diversion Shack: Turbidity & Chlorine Midpoint Shack: Turbidity & Chlorine

47 SO2 Building: Chlorine 2 Chlorine meters Upstream & Downstream

48 Diversion Shack: Turbidity Turbidity Meter

49 Filter Building Annex: Turbidity

50 Filter Building Annex: Turbidity Meter Selector on CPU

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52 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 allowed but must be reported.) C. Influent flow shall not exceed XX MGD average dry weather 5-day period D. Sanitary Sewer Overflows are prohibited

53 2-hour notification a) State OES b) Local Health Officer c) Water Board 24-hour certification to Water Board One written report is OK 5-day written report

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55 1. State Office of Emergency Services: Local Health Officer / Director of Environmental Health: (Santa Clara County Communications Center) (911) 3. Regional Water Quality Control Board Spill Report:

56 24 hour phone report to Water Board if not contained or cleaned up 5 working day written / electronic report to Water Board Report spills to State OES if applicable Is that all???

57 Spill of one barrel of petroleum (42 gallons) 1. State Office of Emergency Services: County Communications Center -- XXXXXX (911) Spill of any oil to waters of the state 1. EPA Region 9 2. National Response Center

58 1. Records (Attachments D & G) 2. Effluent Limitations (Permit & MRP/Attachment E) Requirements to continuously monitor or sample: Turbidity, Chlorine, Bacteria, Dissolved Oxygen, ph 3. Discharge prohibitions (Permit & Attachment G) 2-hour reporting of sewage spills

59 Wastewater Treatment Plant Compliance Surviving an NPDES Permit Inspection General info about permits, limits, & reporting Can you do it? Yes!