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.
.