Inspection: Ready or Not
A little preparation can go a long way toward easing compliance worries
AFTER a day of field work on the road, some guys like to work out, have
dinner and drink a few beers, and talk about sports, fishing, politics, or new gadgets. My buddy Ron Trygar and I tend to talk about wastewater stuff. We just can’t seem to leave it at the plant site at day’s end. We like to describe it as passion and deny that the ongoing banter is obsession.
One evening, the topic was regulatory inspections. How are they structured? How do you prepare for them? Why do some inspectors finish in two hours and others take all day? In fact, managers we know had described regulatory inspections as a mystery or a “blackbox process.” The inspector toured the facilities, asked some questions, took notes, and generally seemed pleased during the exit interview. Then you waited for a formal report—sometimes very positive and sometimes not.
No training for inspections
The U.S. EPA National Pollutant Discharge Elimination System Compliance Inspection
Manual is more than 800 pages in length. Maybe that has something to do with the variation in how much time an inspection takes; what the inspector focuses on; and how the results are interpreted. Trygar and I know that most wastewater utility staff have never really received training about how to prepare for these inspections. We decided to create a formal instructional program to address this void. We also decided it should be visual. More on that later.
Several kinds of regulatory inspections— compliance, performance, or reconnaissance—
are a simple fact of life at a wastewater treatment facility. Generally performed on an annual basis, they combine a detailed review of documents with a walk-through of the facilities. Other inspections might be conducted with a focus on sampling, bio-monitoring, or pretreatment programs. State inspections may be scheduled in advance with the utility manager, while EPA-led inspections typically are unannounced.
Inspectors likely will have reviewed various monitoring reports and records before arriving, so facility managers would be prudent in keeping the following documents up-to-date and readily available at all times:
• discharge monitoring reports (DMRs),
• recent toxicity testing results,
• pathogen monitoring results,
• disinfection monitoring results,
• sludge vector attraction and pathogen monitoring records,
• annual reuse forms (if applicable), and
• groundwater monitoring records.
After introductions are made, a regulatory inspector will examine process treatment units,
sampling and flow-monitoring equipment, outfalls, and the receiving stream. In particular, the inspector focuses on areas where pollutants are generated, pumped, conveyed, treated, stored, or disposed. The basic objectives of a facility site review are to:
• assess the conditions of the facility's current
• evaluate the permittee's operation and maintenance activities,
• check the completeness and accuracy of the permittee's performance/compliance records, and
• determine whether the treatment units are achieving the required treatment efficiencies.
Having the right answer is key
Based on our experience, the odds of receiving high marks from these inspections is predicated on facility staff being able to answer “YES” to the following fundamental questions:
• Is the overall site clean and secure?
• Are sampling points labeled and representative and are samples collected and maintained through clean tubing at correct temperatures?
• Does the grit and screenings area appear to be well managed?
• Are all flowmeters properly calibrated and tagged?
• Are all on-line instruments (pH, turbidity, dissolved oxygen, etc.) routinely maintained, calibrated, and documented?
• Is all “critical equipment” operational?
• Are you satisfied with the visual appearance of all processes? There should be no excessive scum, foam, or objectionable odors.
• Are your processes being operated and monitored with a strategy?
• Is the solids thickening/dewatering area clean?
• Is the disinfection area (UV or chemical) clean, functional, and performing effectively?
• Do you have properly prepared chain-of-custody documents?
• Has the equipment in the laboratory been serviced, calibrated, and tagged?
• Are your lab bench sheets properly filled out and organized?
• Do you have a laboratory quantitative analysis/quality control plan? Are you using it?
• Are you maintaining biosolids records—volumes, characteristics, disposal activities?
• Are standby power generators operable, maintained, and ready for use?
• Do you have your plans in order: Risk Management Plan (RMP), Spill Prevention Control and Countermeasures (SPCC), emergency action standard operating procedures (SOPs)?
Preparing for inspections should be happening all the time within daily work activities.
All staff should be trained about the inspection objectives, focal points, and the process itself.
Trygar and I ended up collaborating with USA Bluebook and the City of Tallahassee, Fla., to produce an inspection training guide, “Wastewater Regulatory Inspections: A Visual Guide to High Performance.” We were filmed touring a Tallahassee facility as inspectors and pointing out key elements of compliance performance, unit process by unit process. Our results are presented to the facility management team at the end of the program. We thought a DVD would serve as an ideal training resource because a facilitator can stop the film at any point and lead a more detailed discussion about a particular topic.
I’m certain at this point you have at least two more questions: The answers are “no, we do not receive any royalties” and “yes, there is an alternative training reference.” You can always read that 800-page inspection manual.
This article originally appeared in the 09/01/2007 issue of Environmental Protection.