It should be easy preparing for an inspection of your wastewater treatment facility mainly because you should already be following most of the steps that would make it a successful inspection in the first place. But the EPA usually doesn't give operators advance notice. That's why it is important to hone the skills necessary to be a successful operator: the ability to manage people efficiently, the knowledge of microbiology and chemistry to perform accurate lab tests, and the experience with the equipment that keeps the facility running smoothly.
But as the industry ages (one APWA study indicates that about half of the operators at the nation's wastewater treatment plants could retire within the next decade), current operators need to ensure that they are supplying the next generation with those skills.
The successful inspections are the result of a work culture that promotes quality control every day, not just on inspection day, says Michael Cherniak, senior vice president of Woodard & Curran (http://www.woodardcurran.com/default.aspx) consulting firm. Follow these steps for a successful inspection, he says:
Prior to the inspection:
- Ensure curb appeal. "If as an inspector I see hoses laying on the ground and parts laying out, I can expect that when I get into the lab I might not like what I see," Cherniak says. "If inspectors see a plant that is clean and orderly but has compliance problems, they'll probably be more forgiving and listen to you a little more." He suggests the occasional spruce-up, including painting and landscaping in addition to basic housekeeping duties such as rolling up hoses and removing debris.
- Keep copies of your National Pollutant Discharge Elimination System (NPDES) permit (http://cfpub.epa.gov/npdes), 90 days of discharge monitoring reports, recent whole effluent toxicity results, a recent 503 biosolids report, copies of nuisance complaints, and chain-of-custodies analyses in a binder for easy perusal by the inspector.
- Regularly replace the tubing on your composite samplers. It's not expensive, and it makes a good impression.
- Ensure that all flow meters are properly calibrated and tagged and that on line instruments (such as those that measure the pH and turbidity) are routinely calibrated and maintained as well.
- Keep "critical equipment" (such as the headworks, blowers, filters, and generators) working efficiently.
- Make sure that the solids thickening/dewatering area and the chlorine tank is clean. "You should be able to see the bottom of the tank if it's clean," Cherniak adds.
- Keep organized files of laboratory bench sheets. Cherniak says that one EPA inspection at a 4-mgd facility lasted just 45 minutes-all because every bottle in the lab was labeled properly. "It told her that everything else, from the operations to the record keeping, was all in order," he says.
The day of the inspection:
- Greet the inspector upon arrival and offer to accompany him on the inspection (but expect that he'll want to conduct the inspection alone). He likely will collect samples, take photos, and interview staff.
- Ask questions and take notes afterward. There's also no reason you can't also ask about potential new regulations that might affect your facility.
- Michael Fielding
Session: Preparing for a Successful Wastewater Regulatory Inspection
Michael Cherniak, CET
Senior Vice President, Woodard & Curran, Portland, Maine
Sun., Aug. 17, 2008