Industrial Pretreatment Inspection Basics Florida Industrial Pretreatment Association Workshop April 25, 2008 Dan Parnell JEA Industrial Pretreatment
Inspection Overview • Things you need to think about • Preparation • Conducting the annual inspection • Spill plans • What ifs….
Types of Inspection • Annual • Spot or Demand • Pre-permit • Sampling
Annual Inspections – Things to Think About • Why? • Meet FDEP & EPA requirements • Verify compliance w/ permit • Identify changes at facility • Maintain relationship w/ IU community • When? Annually
Annual Inspections – More Things to Think About • What? Find and trace all established waste streams (process) and potential waste streams (aka spills). • How? Trace all raw materials coming in, processing through, and product (waste too!) leaving the facility.
Annual Inspections – Even More Things to Think About • To schedule or not to schedule • Unscheduled – no prior notice given to IU • More representative of daily operations • Suggested if IU is having compliance issues • Surprise factor - IU may not have best personnel on site that day
Annual Inspections – Ready for Multitudes of Things to Think About? • To schedule or not to schedule • Scheduled • How much advance notice? • More likely to have best suited IU representative present, leads to quality inspection • Establishes better rapport w/ industries
Annual Inspections – Its Friday Afternoon, Your Probably Tired of Thinking About Things • Frequency • Requirement: once every 12 months • When is increased frequency appropriate? • Compliance history • Type of processes • High hydraulic and pollutant loadings • Seasonal production rates
Annual Inspection - Phases • Planning & Prep • Inspection • Spill Control Plan • Write Report
Annual Inspection – The Inspection Phases • Pre-inspection meeting • Document Review • Physical inspection • Post inspection meeting
Annual Inspection – Pre-inspection Meeting Getting in • Introduce yourself & purpose • Show credentials • Consent must be given to conduct inspection • Sign in Log waivers or releases
Annual Inspection – Pre-inspection Meeting • Discuss: • Reason for inspection • Paperwork to review • Areas to visit • Safety - PPE
Annual Inspection – Doc Review Docs to review: • Waste manifest • Lab documents • Lab data • QA/QC • COC • Flow & pH logs • Pretreatment system operational logs • Documents required due to categorical regulations
Annual Inspection – Physical Inspection • Process Areas: • Tips: • control pace • keep ‘em talking • explore (but ask!) • look for overhead pipes • Where to visit: • water de-mineralization • mix tanks • production lines • clean in place systems • loading docks
Annual Inspection – Physical Inspection Process Areas: The only good drain is a sealed drain. Trays… Drains… and Autofills!
Annual Inspection – Physical Inspection Organic Chemical Manufacturing Process • Process Areas: • Categorical considerations Noncontact Cooling water Vehicle Maintenance Sample Point
Annual Inspection – Physical Inspection Boiler Rooms & Cooling Towers
Annual Inspection – Physical Inspection Chemical Storage Areas The Good Berm, Baby Berm! The Bad The Ugly!
Annual Inspection – Physical Inspection • Pretreatment • Removal technologies
Annual Inspection – Physical Inspection • Pretreatment • Solids Handling
Annual Inspection – Physical Inspection Sample Point & Flow Measurement
Annual Inspection – Post Inspection • Review findings w/ representative • Discuss deficiencies/corrective actions • Use opportunity • To discuss any anticipated changes in IP program • Answer (or refer) questions IU may have concerning utility
Annual Inspection – Spill Plan • Review each SIUs need for a spill plan every 2 years
Annual Inspection – Report • Review notes • Write report • Timeliness • Document everything • No blanks • Send follow up letter: bad & good
What If… • consent for inspection not given? • IU delays entry? • IU won’t let you take pictures? • you feel safety is jeopardized during inspection? • consent is given & later withdrawn? • escort must leave and tells you to finish on your own? • IU claims inspection results are confidential? • you find a garden hose discharging to their sample point?
Inspection Conclusions Quality inspections are accomplished through preparation, understanding what to look for, and knowing where to find it. .