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

People 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 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

Thank You