Will You Be Ready for Your Next Pretreatment Compliance Inspection?

Ellis Insights Wastewater

Pretreatment Compliance Inspection

Pretreatment regulations require that the POTW (Publicly Owned Treatment Works) conduct annual inspections of industrial dischargers as part of their NPDES Permit. 

Why is My Facility Being Inspected?

The POTW’s NPDES Permit requires a minimum, one annual facility inspection.  This is referred to as a Compliance Inspection.  Most Pretreatment Inspectors will make an appointment for the annual inspection due to the detail involved in Part of the inspection is a thorough review of records, process, equipment, and facilities (indoor and outdoor). Due to the detail some POTWs may even send a Pretreatment Inspection form to reduce time reviewing paperwork. 

Surprise inspections, with no advanced warnings are also a possibility.  Industrial Pretreatment Inspectors have the authority to enter any facility to inspect wastewater treatment systems and effluent discharges.  Search warrants are not required for inspectors to enter the premises, collect samples, or make an inspection.  Not allowing a pretreatment inspector on-site can result in serious consequences.  The consequences can involve a search warrant as well as a visit from local law enforcement. 

Surprise inspections may occur due to citizen complaints from neighbors or even from competitors.  Complaints may even come from disgruntled or terminated employees making statements of improper industrial activities.  These complaints have to be investigated whether the allegations are false or true.   

Other unannounced inspections may be follow-up due to Compliance Orders or Enforcement Actions. Issues such as fish kills, wastewater bypasses or major operational upsets at the POTW will also bring out the Pretreatment Inspectors to check areas to search for unauthorized discharges or releases of wastewater or chemicals. 

How are Inspections Conducted?

  • Pre-Inspection Conference
  • Review of Records
  • Facility Walk-Through
  • Wastewater Sample Collection
  • Facility and Pretreatment System Photos
  • Employee Interviews
  • Closing Conference

 Pre-Inspection Conference

  • The Purpose of the Pre-Inspection Conference is to outline what the Inspector will review, what will be inspected, samples collected, areas to be photographed, and possible interviews with staff.
  • The Inspector may also be looking at other environmentally regulated areas pertaining to the Clean Air Act (CAA), Clean Water Act (CWA), Storm Water (SW) and Resource Conservation Recovery Act (RCRA Hazardous Waste). 

Review of Records

  • The Industrial Pretreatment Inspector will not review OSHA records.
  • The following records will be reviewed:
    • Industrial Pretreatment Discharge Permit or NPDES Permit if effluents are discharged to waterways.
      • The Inspector Pays close attention to expiration dates.
      • (Need to reapply for new permit six months in advance of expiration date). 
    • Storm Water Discharge Permits
      • The Inspector Pays close attention to expiration dates.
      • (Need to reapply for new permit six months in advance of expiration date).  
    • Operator Certification Records
      • Operator Certificate with expiration date must be posted with in wastewater room.
    • Self-Monitoring Reports tracking compliance
    • Discharge Monitoring Reports (DMRs) 
    • Compliance Order Status
      • What milestones have occurred to achieve compliance again?
  • Laboratory Analytical Data Record Accuracy
    • Must follow 40 CFR 136 Guidelines (These are USEPA required analytical methods).
  • Sample Collection Procedures and Record Accuracy
    • Grab Samples or Composite Samples
    • Proper Sample Preservation
    • Sample holding times reviewed to ensure time is not exceeded
  • Chain of Custody for Samples Collection Records
    • Paper Trail of where samples went and who handled them
    • Every person who had access to the samples must be recorded
    • Proper Signatures – Each person must sign off
    • Dates and Times must be recorded
  • Equipment Calibration Records
    • Wastewater Flow Meters must be calibrated annually by an outside contractor.
    • pH probes and controllers must be calibrated daily
  • Operator Log Sheet Records
    • Daily pH
    • Flow Monitoring Data
    • Chemical Dosages and Feed Rates
    • Effluent Clarity
  • Sludge Disposal Records
    • Nonhazardous Sludge
      • Sludge Disposal Permit with expiration date
      • Sludge Disposal Manifests with dates
      • Bill of Lading with dates
      • Waste Characterization Records with testing date
      • Hazardous Sludge
        • Sludge Disposal Permit with date
        • Sludge Disposal Manifests with dates
        • Bills of Lading with dates
        • Laboratory Analytical Reports with dates
  • Written PlansWastewater Slug Discharge PreventionInventory of Hazardous Liquids
  • Toxic Organic Management Plan (TOMP)
    • State Approval Required
    • Allows no toxic organic compounds to be discharged to the sewer.
    • Spill Action Plans
      • Spill Prevention Program Records
      • Containment Equipment
      • Countermeasures to Control Spills

Walk-Through Inspection

  • What will the Inspector look for?
  • A Well Operating System
  • Wastewater Operator’s License
  • No Leaks or Spills on the floor
  • A Clean Work Environment
  • Posted Procedures
  • State of the Art Equipment
  • Posted Standard Operating Procedures
  • Validation that equipment actually being used?
  • Treatment chemical application procedures
  • Treatability Study Equipment
  • Treatment Chemical Invoices
  • Sludge Disposal Manifests
  • Maintenance Department (Back Up Equipment – Spare Parts)
  • Secondary Containment for Hazardous Materials
    • POTWs biggest concern are slug loads of spilled chemical or untreated wastewater being released into the sewer.
    • Posted Procedures
    • Spill Control Kits
  • Effluent Quality
    • Solids Carry Over
    • Turbidity – Clarity
    • Odors
    • Sampling point (Parshall flume) and
    • Sample Compositor (refrigerated)
  • Process Changes since last inspection?
    • Some changes may need to be reported to POTW prior to inspection for changes in discharge permit
    • How does the system work?
    • What is design capacity?
    • What is process flow rate?
    • Operations and Maintenance Manuals
    • Equipment Manuals
    • Standard Operating Procedures (SOP)
    • Back up Equipment
    • Posted Discharge Permit Limits
    • Quality Control Limits
    • Spill Response Procedures 
    • Inspector May Take Photos
  • Storage Areas and Holding Tanks
  • Process Chemical Storage Area
  • Wastewater Treatment Chemical Storage Area
  • Wastewater Holding Tanks
  • Hazardous Waste Storage Area
  • Hazardous Material Storage Area
  • Spill Containment Material in Area
  • Spill Clean Up Equipment
  • No Floor Drains in Area
  • Outside of Facility
    • Chemical Storage Areas
    • Holding Storage Tanks
    • Storm Water Pollution Indicators
      • Oil Sheen in Drains
      • Excessive Rust
      • Dead Grass
    • Parking lot drain inspection
    • City Sampling Point (Manhole)

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