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Industrial Pretreatment Inspection Basics

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….

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Industrial Pretreatment Inspection Basics

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  1. Industrial Pretreatment Inspection Basics Florida Industrial Pretreatment Association Workshop April 25, 2008 Dan Parnell JEA Industrial Pretreatment

  2. Inspection Overview • Things you need to think about • Preparation • Conducting the annual inspection • Spill plans • What ifs….

  3. Types of Inspection • Annual • Spot or Demand • Pre-permit • Sampling

  4. 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

  5. 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.

  6. 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

  7. 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

  8. 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

  9. Annual Inspection - Phases • Planning & Prep • Inspection • Spill Control Plan • Write Report

  10. Annual Inspection Planning & Prep

  11. Annual Inspection – The Inspection Phases • Pre-inspection meeting • Document Review • Physical inspection • Post inspection meeting

  12. 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

  13. Annual Inspection – Pre-inspection Meeting • Discuss: • Reason for inspection • Paperwork to review • Areas to visit • Safety - PPE

  14. 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

  15. 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

  16. Annual Inspection – Physical Inspection Process Areas: The only good drain is a sealed drain. Trays… Drains… and Autofills!

  17. Annual Inspection – Physical Inspection Organic Chemical Manufacturing Process • Process Areas: • Categorical considerations Noncontact Cooling water Vehicle Maintenance Sample Point

  18. Annual Inspection – Physical Inspection Boiler Rooms & Cooling Towers

  19. Annual Inspection – Physical Inspection Chemical Storage Areas The Good Berm, Baby Berm! The Bad The Ugly!

  20. Annual Inspection – Physical Inspection • Pretreatment • Removal technologies

  21. Annual Inspection – Physical Inspection • Pretreatment • Solids Handling

  22. Annual Inspection – Physical Inspection Sample Point & Flow Measurement

  23. 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

  24. Annual Inspection – Spill Plan • Review each SIUs need for a spill plan every 2 years

  25. Annual Inspection – Report • Review notes • Write report • Timeliness • Document everything • No blanks • Send follow up letter: bad & good

  26. 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?

  27. Inspection Conclusions Quality inspections are accomplished through preparation, understanding what to look for, and knowing where to find it. .

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