1. Industrial User Inspections EPA Region 9, Clean Water Act Compliance Office CWEA 39 th February 29, 2012 Huntington Beach Greg V. Arthur US EPA (WTR-7), 75 Hawthorne Street, San Francisco, 94601 (415) 972-3504 arthur.greg@epa.gov

2. Industrial User Inspections Key - Account for the sources of variability in discharge quality Fed Regulatory Fed Regulatory Requirements Requirements Types of Inspections Types of Inspections Conducting the Conducting the Inspections Inspections Sources of Variability Sources of Variability Permit Verification Permit Verification Representative Representative Sampling Sampling Bypass / Dilution Bypass / Dilution batch industrial wastewater treatment unit for oil and toxic shipyard process waters 

3. Industrial User Inspections Key - Account for the sources of variability in discharge quality Fed Regulatory Requirements 40 CFR 403.8(f)(2)(v) POTWs must determine compliance independent of the information provided by the discharger sampling sampling inspection inspection verification verification portable pump with long extension hoses in an electroplating shop 

4. Industrial User Inspections Key is to find the sources of the variability in discharge quality Inspections Types Unannounced Unannounced Announced Announced Sampling Sampling Non-Sampling Non-Sampling Walk-Through Walk-Through Comprehensive Comprehensive Civil Enforcement Civil Enforcement Criminal Investigation Criminal Investigation batch industrial wastewater treatment unit for spent solutions and IX regenerant 

5. Industrial User Inspections Key is to find the sources of the variability in discharge quality Conducting Inspections Ultimately industrial users meet effluent limits by controlling the variabilities, inherent in their design and operations, that effect the wastewater quality. continuous pH and ORP metering for treatment found not in service

6. pH and ORP probes evidently not used recently continuous pH and ORP metering for treatment found not in service Industrial User Inspections Key is to find the sources of the variability in discharge quality Conducting Inspections So … focus field work on identifying and quantifying sources and controls of variabilities from operations operations treatment treatment discharge discharge 

7. Industrial User Inspections Key is to find the sources of the variability in discharge quality Conducting Inspections Step 1 Step 1 First follow the indus- First follow the indus- trial processing steps trial processing steps (raw materials in to (raw materials in to final products out). final products out). open drums, portable pump and hosing, floor staining – general uncontrolled mess

8. Industrial User Inspections Key is to find the sources of the variability in discharge quality Conducting Inspections Step 1 - Along the way identify all identify all wastestreams wastestreams determine determine controls for each controls for each determine all determine all methods of delivery methods of delivery verify the verify the pollutants present pollutants present verify process verify process and start-up dates and start-up dates open drums, portable pump and hosing, floor staining – general uncontrolled mess 

9. Industrial User Inspections Key is to find the sources of the variability in discharge quality Conducting Inspections Step 2 Step 2 Inspect all treatment Inspect all treatment units and methods of units and methods of pollution control and pollution control and wastewater handling wastewater handling practices practices industrial wastewater treatment unit with final storage and equalization

10. Industrial User Inspections Key is to find the sources of the variability in discharge quality Conducting Inspections Step 2 - At control units identify all identify all incoming sources incoming sources identify reaction identify reaction end-point controls end-point controls determine methods determine methods of internal delivery of internal delivery verify reagents and verify reagents and pollutants present pollutants present identify all outgoing identify all outgoing wastestreams wastestreams industrial wastewater treatment unit with final storage and equalization 

11. Industrial User Inspections Key is to find the sources of the variability in discharge quality Conducting Inspections Step 3 Step 3 Verify sample points, Verify sample points, sampling frequencies, sampling frequencies, and pollutants and pollutants sampled against sampled against pollutants present pollutants present sewer connection discharge point with multiple wastewater inlets

12. Industrial User Inspections Key is to find the sources of the variability in discharge quality Conducting Inspections Step 3 - Disposal determine if sampling determine if sampling accounts for all flows accounts for all flows verify sample day verify sample day representativeness representativeness verify representativ- verify representativ- ness over time ness over time determine determine methods of disposal methods of disposal verify sampling covers verify sampling covers pollutants present pollutants present sewer connection discharge point with multiple wastewater inlets 

13. industrial wastewater treatment unit with continuous reaction end-point metering Industrial User Inspections Key is to find the sources of the variability in discharge quality Conducting Inspections Step 4 Step 4 Get enough detail to Get enough detail to draw a wastewater draw a wastewater control schematic control schematic

14. WastewaterControlSchematic Level of Detail sources sources and schedules and schedules methods of methods of delivery delivery methods of methods of control control unit process unit process monitoring monitoring methods of methods of disposal disposal

15. Industrial User Inspections Key is to find the sources of the variability in discharge quality Conducting Inspections Step 4 - Schematic sources sources and schedules and schedules methods of methods of delivery delivery methods of methods of control control unit process unit process monitoring monitoring methods of methods of disposal disposal industrial wastewater treatment unit with continuous reaction end-point metering Metering for chrome reduction chrome reduction metals precipitation metals precipitation cyanide destruction cyanide destruction 

16. Industrial User Inspections Key is to find the sources of the variability in discharge quality Operational Sources of Variability Variabilities in waste- water generation are the result of the way the industry operates and in how the wastes are then collected, delivered, treated, and conveyed for disposal. bosses - operators - contractors - grunts and a couple of plating shop dudes

17. bosses - operators - contractors - grunts and a couple of plating shop dudes Industrial User Inspections Examples of variabilities related to operations Variability in Flow seasonal seasonal weekends weekends swing shift swing shift timer timer scheduled overhaul scheduled overhaul CIP CIP 

18. Industrial User Inspections Examples of variabilities related to operations Variability in Pollutant Loadings spents spents circulation bleeds circulation bleeds regenerant / reject regenerant / reject concentrates concentrates CIP tank flush CIP tank flush sump drainage sump drainage treatment unit treatment unit tailwaters tailwaters floor drains - wet floors 

19. Industrial User Inspections Examples of variabilities related to operations Wastewater Segregation by Strength high-strength high-strength spents spents drag-out spents drag-out spents IX regenerant IX regenerant low-strength low-strength overflow rinses overflow rinses washdown washdown hydrotest hydrotest uncontaminated uncontaminated RO/IX brines RO/IX brines domestic sources domestic sources hardpiping of spents by type to segre- gated batch treatment + clear labeling 

20. Industrial User Inspections Examples of variabilities related to operations Wastewater Segregation by Treatability cyanide-bearing cyanide-bearing acids acids alkalines alkalines oily emulsions oily emulsions brines brines solids and slurries solids and slurries insoluble organics insoluble organics soluble organics soluble organics volatile organics volatile organics separate tanks for different types of batch treatment steps 

21. on-demand low-overflow rinsing Industrial User Inspections Examples of variabilities related to operations Process Water Consumption Practices on-demand on-demand countercurrent countercurrent dilution dilution DI make-up DI make-up IX in-tank circulation IX in-tank circulation CIP schedules CIP schedules 

22. Industrial User Inspections Key is to find the sources of the variability in discharge quality Treatment-Related Sources of Variability Treatment reduces variability in effluent quality (1) by reducing mean concentrations and (2) because effec- tive treatment requires control of the influent quality, delivery, and treatment processes. oily wastewater treatment unit for oily bilge and ships wastewater

23. Industrial User Inspections Examples of variabilities related to treatment separate treatment separate treatment by strength by strength reaction end-points reaction end-points reaction interference reaction interference settling / filtration settling / filtration design capacity design capacity surges surges short-circuiting short-circuiting clogging clogging solids handling solids handling variability controls variability controls equalization equalization metering metering oily wastewater treatment unit for oily bilge and ships wastewater 

24. segregated wastewaters collected for off-site disposal Industrial User Inspections Key is to find the sources of the variability in discharge quality Discharge-Related Sources of Variability The methods of dis- charge and disposal can significantly reduce the variabilities in the effluent quality.

25. segregated wastewaters collected for off-site disposal Industrial User Inspections Examples of variabilities related to the method of discharge combined discharge combined discharge batch discharge batch discharge metered discharge metered discharge final equalization final equalization test prior to discharge test prior to discharge off-site disposal off-site disposal 

26. Industrial User Inspections Key is to find the sources of the variability in discharge quality Permit Verification Federal standards are generally based on BAT for certain dis- charges. Federal standards are statistically-based to reflect what BAT can nearly always achieve (not on average). multiple discharges from continuous and batch treatment units to single outlet

27. Industrial User Inspections Key is to find the sources of the variability in discharge quality Permit Verification Federal standards apply end-of-process and after treatment (unless adjusted). Local limits apply end-of-pipe.

28. multiple discharges from continuous and batch treatment units to single outlet Industrial User Inspections Key is to find the sources of the variability in discharge quality Permit Verification New source standards are generally based on the same BAT for con- centrated discharges resulting from waste- water recycling or reuse.

29. Industrial User Inspections Key is to find the sources of the variability in discharge quality Permit Verification New source standards apply to wastestreams from new processes as well from some old ones in which a new upgrade provided the opportunity to also upgrade pollution controls. multiple discharges from continuous and batch treatment units to single outlet 

30. Industrial User Inspections EPA Region 9, Clean Water Act Compliance Office CWEA 39th Annual P3S Conference Huntington Beach, CA February 29, 2012 Greg V. Arthur US EPA (WTR-7), 75 Hawthorne Street, San Francisco, 94601 (415) 972-3504 arthur.greg@epa.gov