Surviving an NPDES Permit Inspection (National Pollutant Discharge Elimination System) General info about permits & reporting

Transcription

1 Wastewater Treatment Plant Compliance Surviving an NPDES Permit Inspection (National Pollutant Discharge Elimination System) General info about permits & 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

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 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)

7 Get Ready It s going to happen. 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 You - before Have a Plan 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

9 Know what your inspector wants: The Checklist

10 Know what your inspector wants: The Last Inspection

11 Get People Ready alert

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

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

14 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!

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

16 Wastewater Facilities Status Report (Attachment G, 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

17 A Tip - Use your Annual SMR Report as a Wastewater Facilities Status Report Annual SMR Report Table of Contents Staffed, Supervised, Financed, Operated, Maintained, Repaired, Upgraded

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

19 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?

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

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

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

23 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.

24 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

25 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.

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

27 Tour Stop 2 - Primary Primary Clarifiers Scum Separators

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

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

30 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

31 The thank you

32 You - before Have a Plan 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

33 Wastewater Treatment Plant Compliance Surviving an NPDES Permit Inspection (National Pollutant Discharge Elimination System) General info about permits & reporting

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

35 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

36 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

37 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

38 Raw Sewage Floating & suspended material Discoloration & turbidity Odor

39 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

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

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 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

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

45 Effluent: EFF-001 Influent: INF-001 AKA: Raw Sewage

46 Weir Bridge & SO2 Building: DO, ph, Chlorine NPDES Recycled Water 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

47 SO2 Building: Chlorine 2 Chlorine meters Upstream & Downstream

48 Courtesy Sign Computer Selector Red Button Take meters offline when calibrating

49

50 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!

51 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

52

53 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:

54 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???

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

56 Wastewater Treatment Plant Compliance Surviving an NPDES Permit Inspection (National Pollutant Discharge Elimination System) General info about permits & reporting Do you think you can pass? Yes!