Florida Industrial Pretreatment Association Workshop

April 25, 2008Dan Parnell

JEA Industrial Pretreatment

Inspection OverviewThings you need to think aboutPreparationConducting the annual inspectionSpill plansWhat ifs….

Types of InspectionAnnual Spot or DemandPre-permitSampling

Annual Inspections – Things to Think AboutWhy?

Meet FDEP & EPA requirementsVerify compliance w/ permitIdentify changes at facilityMaintain relationship w/ IU community

When? Annually

Annual Inspections – More Things to Think AboutWhat?

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 AboutTo 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 scheduleScheduled

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 ThingsFrequency

Requirement: once every 12 monthsWhen is increased frequency appropriate?

Compliance history Type of processes High hydraulic and pollutant loadings Seasonal production rates

Annual Inspection - PhasesPlanning & PrepInspection Spill Control PlanWrite Report

Annual Inspection Planning & Prep

Annual Inspection – The InspectionPhases

Pre-inspection meetingDocument ReviewPhysical inspectionPost inspection meeting

Annual Inspection – Pre-inspection MeetingGetting in

Introduce yourself & purposeShow credentialsConsent must be given to conduct inspection

Sign in Log waivers or releases

Annual Inspection – Pre-inspection MeetingDiscuss:• Reason for inspection• Paperwork to review• Areas to visit• Safety - PPE

Annual Inspection – Doc ReviewDocs to review:

Waste manifestLab documents

Lab data QA/QC COC

Flow & pH logsPretreatment system

operational logsDocuments 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

Drains…

Process Areas:Trays…

and Autofills!

The only good

drain is a sealed drain.

Annual Inspection – Physical InspectionProcess Areas:Categorical considerations

Organic Chemical Manufacturing

Process

Sample

Point

Noncontact Cooling water

Vehicle Maintenan

ce

Annual Inspection – Physical InspectionBoiler Rooms & Cooling Towers

Annual Inspection – Physical InspectionChemical Storage Areas

Berm, Baby Berm!

The Good

The Ugly!

The Bad

Annual Inspection – Physical InspectionPretreatment• Removal technologies

Annual Inspection – Physical InspectionPretreatment• Solids Handling

Annual Inspection – Physical InspectionSample 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 ConclusionsQuality inspections are accomplished through

preparation, understanding what to look for, and knowing where to find it.

.