Transcript Spring Training 2008
Spring Training 2008
IPP INSPECTION
PURPOSE OF INSPECTION
• The main purpose of an industrial waste pretreatment program is to protect the environment, the POTW facilities, the personnel, and to protect the local community from adverse effects due to industrial waste discharges.
PURPOSE • Protection of Capital facilities; clogs, blockage, corrosion, explosion, coating of system, plant overloading, endangerment of staff, and ?
• Protection of Community; Odors, Gases, Organics, Pathogens, and ?
PURPOSE • Compliance of Regulations; EPA, State of Michigan, Local CFR, Approved IPP Program, local Ordinance Financial; Fees, Water & Waste (Clean) Water
Definition • What is a BMR?
• A. name and address of facility • B list of all environmental permits • C brief description; of business nature, average production rates, SIC code for each operation, flow measurement for regulated discharge, and record ofof test data to each stream, statements of certification concerning compliance, and procedure to achieve compliance if needed.
Definition • What is a SIU?
• A all categorical users • B non-categorical user that; discharges 25,000 + gal/day of process water excluding non-contact waters contributes process waters that equal or exceed 5% of more of average dry weather hydraulic or organic (BOD,TSS) capacity of treatment plant
Definition SIU (continue) Has a reasonable potential in the opinion of the control or approval authority to adversely affect the POTW treatment plant (inhibition, Pass through of pollutants, sludge contamination, or endangerment of POTW workers)
Word from the Field
What are we inspecting ?
• Industrial Categorical SIU • Commercials; Food Service, Automotive • Institutional; Universities, Schools, Churches
Type of Inspection • Sampling • Routine Inspection • Surveillance or special Investigation • Emergency Response • System Upsets
Procedure – the prep • Do you have the legal authority to inspect?
• What’s in your permit or ordinance?
• What’s in your Storm water ordinance?
Procedure- File review • BMR • Out fall locations • Sanitary flows for combined stream locations • Facility layout • Pretreatment equipment • Production schedule • Progress reports • Permit revisions • Water use records • Operation schedule • Raw Materials • Location of Chemical storage • Special Permit requirements • Compliance or enforcement actions • Past inspection forms • Self monitoring results • Surcharge or payment records
Procedure – Equipment on Hand • Proper pictured ID • Notebook, pen, pencil • Camera • Safety equipment • Glasses • Hard hat • Safety toe shoes or boots • Ear plugs • Test equipment • Kits for ph or metals etc • Flow meter testing equipment.
• Atmosphere testing device • Sample containers • Manhole opening tools
Word from The Field
The Door • Contact Person • ID pictured • Business card • Your Phone or radio
Entry - Refusal Call the Boss • Leave and collect samples as soon as possible at discharge or upstream/downstream • Before leaving inform them they are in violation of entry provision • Try to reenter later • Issue citation for violation and follow your Enforcement Response Plan • Contact your supervisor and if necessary get a search warrant to enter with police • Plug the facility
• You the inspector • Professional manner • Courteous • To the point • Focused • Know the rules • Follow the rules • Do not push the client for higher standards than required by permit People • Contact Types • Belligerent • Good Buddy • In Charge • Worker Bee • Public Relations • Evasive-NO cooperation • Instructive Expert • Informant
Do the Inspection • Complete Inspection • Outfall • Effluent treatment equipment • In plant control equipment • General plant outfall • Paper work review • MSDS • Slug Plan • Waste Manifest • Inspection review discussion • Discussion of violations
Inspection Follow Up • Reports • Routine • Special Investigation • Enforcement • Compliance Follow up