Wastewater Treatment Facility Inspections: Ready or Not?
After a long day, some people will kick back, have dinner and a drink, and talk about sports or politics. O&M people tend to talk about water and wastewater. We just can’t seem to leave it at the plant at day’s end. We like to describe it as passion and deny that it might be an obsession.
One evening I was talking with a few such passionate people; the topic was regulatory inspections. Some managers have described them as a mystery, a “black box” process. The inspector arrives, tours the facility, asks questions, makes notes, and seems pleased during the exit interview. Then you wait for the report – sometimes it’s very positive and sometimes it’s not. You almost never know what to expect. Why is that?
The National Pollutant Discharge Elimination System Compliance Inspection Manual is more than 800 pages long. Maybe that has something to do with the variation in how an inspection is conducted, what the inspector focuses on, and how the results are interpreted. On the flip side, most water and wastewater utility staff have never really had any training on how to prepare for these inspections.
On this particular night, we decided there ought to be a formal instructional program to address this void. We also decided it should be visual. More on that later.
Regulatory inspections – compliance, performance, or reconnaissance – are a fact of life at wastewater treatment facilities. Generally performed annually, 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 will have reviewed monitoring reports and records before arriving, so facility managers would be wise to keep the following documents up-to-date and readily available at all times:
- discharge monitoring reports,
- 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 treatment processes, evaluate the plant’s operation and maintenance activities, check the completeness and accuracy of performance/compliance records, and determine whether treatment units are meeting the required standards.
Based on our experience, the odds of receiving high marks from these inspections is predicated on facility staff being able to answer “YES” to a list of fundamental questions, including:
- Is the overall site clean and secure?
- Are all flowmeters properly calibrated and tagged?
- 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.
- Is the disinfection area clean, functional, and performing effectively?
- Do you have properly prepared chain of custody documents?
- Are your lab bench sheets properly filled out and organized?
- 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, Spill Prevention Control and Countermeasures, emergency action standard operating procedures?
Preparation for inspections should be happening all the time within daily work activities. All staff should be trained on the inspection objectives, focal points, and the process itself.
SBR guru and good friend Ron Trygar and I ended up collaborating with USA Bluebook and the City of Tallahassee, FL to produce an inspection training guide, Wastewater Regulatory Inspections: A Visual Guide to High Performance. We were filmed performing an inspection of a Tallahassee facility 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 sure 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.
Contributed by Mike Cherniak, CET