United States
Environmental Protection
Agency
Enforcement And
Compliance Assurance
(2223A)
EPA300-B-94-014
September 1994
vvEPA
NPDES
Compliance Inspection
Manual
ENVIRONMENTAL
PROTECTION
I AGENCY
DALLAS, TEXAS
Lil
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NPDES COMPLIANCE
INSPECTION MANUAL
September 1994
U.S. Environmental Protection Agency
Office of Enforcement and Compliance Assurance
401 M Street, SW
Washington, DC 20460
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
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TRANSMITTAL MEMORANDUM
The National Pollutant Discharge Elimination System (NPDES) Compliance Inspection
Manual has been developed to support wastewater inspection personnel in conducting field
inspections fundamental to the NPDES compliance program and to provide inspectors with
standardized procedures for conducting complete, accurate inspections.
This manual is an update of the 1988 NPDES Compliance Inspection Manual. The
modifications include recent changes to the regulations and citations. Authority for the
.NPDES Program is found in Section 402 of the Federal Water Pollution Control Act
(FWPCA).
EPA's approach to performing compliance inspections is currently in transition. The
expansion of this manual reflects EPA's desire to pursue a consolidated inspection
approach where inspectors look beyond statute-specific guidance to carry out their
mission. The Office of Compliance within the recently reorganized Office of Enforcement
and Compliance Assurance is organized on a sector basis which enables the Agency to
promote compliance with all environmental statutes that apply to each sector. New
chapters of this manual covering pollution prevention and multi-media concerns support
this transition to a whole sector approach to compliance improvement.
The information presented in the manual will guide a qualified inspector in conducting an
adequate inspection. The manual presents standard procedures for inspection; it is
assumed the inspector has a working knowledge of wastewater and related problems,
regulations, and control technologies. The manual will serve the experienced inspector as
a flexible and easy reference. New inspection personnel will find support in the orderly and
detailed presentation of the material.
Regional and State personnel are encouraged to provide U.S. Environmental Protection
Agency (EPA) Headquarters with changes or information that would improve the manual.
Comments, information, and suggestions should be addressed to:
Chief, Energy and Transportation Branch (2223A)
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
The information contained in this manual is comprehensive and designed to address a wide
range of activities. Since each inspection may not involve all activities, the inspector
should refer to those parts applicable to the particular inspection. Although the information
is presented from the viewpoint of EPA, it is applicable to NPDES State inspectors and
other regulatory authorities or their authorized representatives.
Manual Organization
The manual is organized into two parts. The first part, on basic inspection components,
consists of seven chapters. The second part includes information on specific types of
inspections.
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Basic Inspection Components
• Chapter One, "Introduction," describes the NPDES program and provides general
information relating to legal authority and inspector responsibilities.
• Chapter Two, "Inspection Procedures," discusses general procedures common to all
NPDES inspections, including pre-inspection preparation, entry, opening conference,
documentation, closing conference, and inspection report.
• Chapters Three through Seven provide the specific technical information necessary
to conduct the full range of NPDES compliance inspection activities. Each chapter
describes procedures for the major technical activities involved in compliance
inspections:
- Chapter Three, Documentation/Recordkeeping and Reporting
- Chapter Four, Facility Site Review
- Chapter Five, Sampling
- Chapter Six, Flow Measurement
- Chapter Seven, Laboratory Procedures and Quality Assurance.
Specific Information
Chapter Eight, Toxicity
Chapter Nine, Pretreatment
Chapter Ten, Sewage Sludge
Chapter Eleven, Storm Water
Chapter Twelve, Combined Sewer Overflows
Chapter Thirteen, Pollution Prevention
Chapter Fourteen, Multi-Media Concerns
Within each chapter, tables illustrate the topics discussed in the text. These are located at
the end of the chapter subsection in which they are referenced. Additional information and
figures are also included in the appendices to the manual. As appropriate, references and
checklists are provided at the end of the chapter. The checklists presented in this manual
are intended as guidance. They can be used as presented or modified to address the
needs of the inspection authority. (More detailed checklists for any individual inspection
type may have also been developed by EPA or State agencies and are presented in the
guidance materials specific to that type of inspection.)
It should be noted that the text often is written from the perspective of the Federal Clean
Water Act requirements. State NPDES inspectors using this manual may find that State
rules and procedures on such topics as notice to the permittees vary to some degree from
the material found in this manual. The technical material will, we hope, prove to be useful
to all NPDES inspectors.
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ACKNOWLEDGMENTS
This document represents an update of the May 1988 manual. We would like to thank the
considerable efforts and cooperation of the persons who reviewed this document and provided
comments.
This manual was prepared under the direction of Gary Polvi. Extensive reviews were
conducted by EPA Headquarters, Regional Offices, and many State agencies during this
update. These reviews provided valuable comments, most of which were incorporated into
this manual.
This manual was revised by Science Applications International Corporation (SAIC) under EPA
Contract No. 68-C8-0066.
in
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DISCLAIMER
This project has been funded, at least in part, with Federal funds from the U.S. Environmental
Protection Agency'(EPA) Office of Enforcement and Compliance Assurance under contract to
SAIC, Contract No. 68-C8-0066, WA Nos. C-4-1 (E) and C-5-1 (E). The mention of trade
names, commercial products, or organizations does not imply endorsement by the U.S.
Government.
IV
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TABLE OF CONTENTS
Contents Page
TRANSMITTAL MEMORANDUM i
1. INTRODUCTION
A Purpose and Objectives 1-1
B Legal Authority for NPDES Inspections 1-7
C Responsibilities of the NPDES Inspector 1-9
2. INSPECTION PROCEDURES
A Pre-lnspection Preparation * 2-1
B Entry 2-9
C Opening Conference 2-13
D Documentation 2-17
E Closing Conference 2-27
F Inspection Report 2-29
3. DOCUMENTATION/RECORDKEEPING AND REPORTING
A Inspection Authority and Objectives 3-1
B Evaluation Procedures 3-3
C Verification, Recordkeeping, and Reporting Evaluation Checklist 3-11
4. FACILITY SITE REVIEW
A Objectives 4-1
B Physical Inspection of the Facility 4-3
C Operation and Maintenance Evaluation 4-15
D References and Facility Site Review Checklist 4-27
5. SAMPLING
A Evaluation of Permittee Sampling Program and Compliance Sampling 5-1
B Sampling Procedures and Techniques 5-3
C References and Permittee Sampling Inspection Checklist 5-25
6. FLOW MEASUREMENT
A Evaluation of Permittee's Flow Measurement 6-1
B Flow Measurement Compliance 6-5
C References and Flow Measurement Inspection Checklist 6-13
7. LABORATORY PROCEDURES AND QUALITY ASSURANCE
A Objectives and Requirements 7-1
B Sample Handling Procedures 7-3
C Laboratory Analyses Techniques Evaluation 7-5
D Quality Assurance and Quality Control 7-9
E References and Laboratory Quality Assurance Checklist 7-15
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Table of Contents
TABLE OF CONTENTS (Continued)
Contents Page
8. TOXICITY
A Objectives 8-1
B Requirements of WET Testing 8-3
C Analysis of Results 8-11
9. PRETREATMENT
A Review of the General Pretreatment Regulations 9-1
B Pretreatment Compliance Inspections (PCIs) and Audits 9-15
C References 9-21
10. SEWAGE SLUDGE
*
A Review of the Sewage Sludge Regulations 10-1
B Sludge Inspection Procedures 10-9
C References 10-31
11. STORM WATER
A Review of the Storm Water Regulations 11-1
B Storm Water Permits 11-15
C Sampling and Inspection Considerations 11-27
D References 11-35
12. COMBINED SEWER OVERFLOWS
A Review of the CSO Policy 12-1
B CSO Inspection Procedures 12-5
C References and Checklist 12-11
13. POLLUTION PREVENTION
A Overview of Pollution Prevention 13-1
B Pollution Prevention Opportunity Assessment Procedures For
Industrial Facilities 13-7
C Pollution Prevention Assessment Procedures For Municipal Wastewater Treatment
Plants 13-15
D References 13-19
14. MULTI-MEDIA CONCERNS
A Introduction 14-1
B Overview of the Multi-Media Approach to Inspections 14-3
C Multi-Media Concerns at NPDES Facilities and the Multi-Media Screening
Program 14-5
D NPDES Inspectors and Multi-Media Inspections 14-9
E References 14-13
VI
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LIST OF TABLES
Table Page
1. INTRODUCTION
1-1 Comparison of Inspection Activities With Inspection Types 1-5
1-2 NPDES-Related Statutes and Regulations 1-8
1-3 Inspector's Responsibilities 1-14
2. INSPECTION PROCEDURES
2-1 List of Field Sampling Equipment 2-8
4. FACILITY SITE REVIEW
4-1 Operation and Maintenance Function Evaluation Questions 4-19
5. SAMPLING
5-1 Volume of Sample Required for Determination of the Various Constituents
of Industrial Wastewater 5-11
5-2 Compositing Methods 5-13
5-3 Required Containers, Preservation Techniques, and Holding Times 5-14
5-4 Quality Control Procedures for Field Analysis and Equipment 5-21
8. TOXICITY
8-1 Recommended Sampling Strategies for Continuous and Intermittent
Discharges for Flow-Through, Static Renewal, and
Static Toxicity Tests 8-9
9. PRETREATMENT
9-1 Summary of the General Pretreatment Regulations 9-8
9-2 Categorical Pretreatment Standards 9-13
10. SEWAGE SLUDGE
10-1 Records Relevant for Sludge Operations 10-20
10-2 Operating Records for Specific Unit Processes 10-21
10-3 Sludge Sampling Points 10-23
10-4 Recordkeeping Requirements for Class A Pathogen Reduction
Alternatives 10-24
10-5 Recordkeeping Requirements for Class B Pathogen Reduction
Alternatives 10-26
10-6 Recordkeeping Requirements for Vector Attraction Reduction Sludge
Processing Options 10-27
VII
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List of Tables
LIST OF TABLES (Continued)
Table Page
10-7 Sludge Handling Process Evaluation 10-28
10-8 Pollutants Monitored for Land Application, Surface Disposal, and
Incineration 10-30
11. STORM WATER
11-1 Summary of 40 CFR 122.26 Storm Water Permitting Regulations 11-11
11-2 Important SIC Codes for Storm Water Discharges 11-12
11-3 NPDES Storm Water Permit Application and Issuance Deadlines 11-13
12. COMBINED SEWER OVERFLOWS
12-1 Nine Minimum CSO Controls 12-3
12-2 Elements of the Long-Term CSO Control Plan 12-3
12-3 CSO Records 12-9
13. POLLUTION PREVENTION
13-1 Useful Facility Information to Conduct a Pollution Prevention Opportunity
Assessment 13-13
VIII
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LIST OF FIGURES
Figure Page
10. SEWAGE SLUDGE
10-1 Sludge Quality Requirements for Land Application Uses 10-7
10-2 Sludge Quality Requirements for Surface Disposal 10-8
11. STORM WATER
11-1 Industrial Categories Associated With Industrial Activity 11-9
11-2 Site-Specific Industrial Storm Water BMPs 11-25
11-3 Site-Specific Construction Storm Water BMPs 11-26
13. POLLUTION PREVENTION
13-1 Waste Management Hierarchy 13-5
13-2 Benefits of Pollution Prevention 13-6
13-3 Pollution Prevention Opportunity Assessment 13-12
IX
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LIST OF APPENDICES
Appendix
1. INTRODUCTION
A EPA Order 1440.2 Health and Safety Requirements for Employees Engaged in
Field Activities
2. INSPECTION PROCEDURES
B Sample Section 308 Letter
C EPA's Memorandum on Entry Procedures
D EPA's Memorandum on Deficiency Notice Guidance
E NPDES Compliance Inspection Report Form 3560-3
5. SAMPLING
F Example Chain-of-Custody Form
6. FLOW MEASUREMENT
G Further Information on Flow Management Devices
8. TOXICITY
H Recommended Effluent Toxicity Test Conditions
10. SEWAGE SLUDGE
I Sludge Inspection Checklists
J Approved Methods for the Analysis of Sewage Sludge (40 CFR Part 503)
11. STORM WATER
K EPA Industrial General Permit Checklist Storm Water Pollution Prevention Plan
Analysis
L Industrial Source Control BMP Questions
M EPA Baseline Construction General Permit Requirements Pre-Construction Checklist
N Construction Source Control BMP Questions
O Monitoring Requirements in EPA's General Permit
P Rain Zones of the United States
Q Typical "c" Coefficients
13. POLLUTION PREVENTION
R Pollution Prevention Checklist
14. MULTI-MEDIA CONCERNS
S Media-Specific Inspection Components
T National Multi-Media Screening Inspection Checklist
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LIST OF ACRONYMS
Acronym
Full Phrase
APHA American Public Health Association
ASTM American Society for Testing and Materials
AWWA American Water Works Association
BAT/BCT Best Available Technology/Best Control Technology
BMP Best Management Practice
BMR Baseline Monitoring Report
BOD Biochemical Oxygen Demand
CAA Clean Air Act
CBI Compliance Biomonitoring Inspection
CEI Compliance Evaluation Inspection
CEM Continuous Emission Monitoring
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CERI Center for Environmental Research Information
CFR Code of Federal Regulations
ChV Chronic Value
COD Chemical Oxygen Demand
COM Continuous Opacity Monitoring
CPLR Cumulative Pollutant Loading Rate
CSI Compliance Sampling Inspection
CSO Combined Sewer Overflow
CSS Combined Sewer System
CWA Clean Water Act
CWF Combined Wastestream Formula
Dl Diagnostic Inspection
DMR Discharge Monitoring Report
DO Dissolved Oxygen
DOI Department of Interior
DOT Department of Transportation
DSS Domestic Sewage Study
DWO Dry Weather Overflow
EC50 Concentration that causes an effect in 50% of the test organisms
EMSL Environmental Monitoring Systems Laboratory
EPA Environmental Protection Agency
EPCRA Emergency Planning and Community Right to Know Act
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FINDS Facility Index System
FR Federal Register
GC Gas Chromatography
GC/MS Gas Chromatography/Mass Spectroscopy
ICP Inductively Coupled Plasma
ID Industrial User
LC Lethal Concentration
LC50 Concentration at which 50% of the test organisms die in a specified time
period
XI
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List of Acronyms
LIST OF ACRONYMS (Continued)
Acronym
Full Phrase
LD50 Dose at which 50% of the test organisms die in a specific time period
LDR Land Disposal Restrictions
LOEC Lowest-Observed-Effect-Concentration
LSI Legal Support Inspection
LTCP Long-Term Control Plan
LVE Low Volume Exemption
MCL Maximum Contaminant Level
MEP Maximum Extent Practicable
MGD Million Gallons per Day
MIT Mechanical Integrity Testing
MPN Most Probable Number
MSWLF Municipal Solid Waste Landfill
MWPP Municipal Water Pollution Prevention
NAAQS National Ambient Air Quality Standards
NEIC National Enforcement Investigation Center
NESHAPS National Emission Standards for Hazardous Air Pollutants
NOC Notice of Commencement
NOEC No Observable Effect Concentration
NOI Notice of Intent
NOT Notice of Termination
NPDES National Pollutant Discharge Elimination System
NSPS New Source Performance Standards
NURP National Urban Runoff Program
O&M Operations and Maintenance
OSHA Occupational Safety and Health Administration
PAI Performance Audit Inspection
PCB Polychlorinated Biphenyl
PCI Pretreatment Compliance Inspection
PCS Permit Compliance System
PFRP Processes to Further Reduce Pathogens
PIES Pollution Information Exchange System
PIRT Pretreatment Implementation Review Task Force
PL Public Law
PMN Premanufacture Notification
POTW Publicly Owned Treatment Works
PPETS Pretreatment Permits and Enforcement Tracking System
PPIC Pollution Prevention Information Clearinghouse
PSD Prevention Significant Deterioration
PSRP Processes to Significantly Reduce Pathogens
QA Quality Assurance
QC Quality Control
QNCR Quarterly Noncompliance Report
R&D Research and Development
RBC Rotating Biological Contactor
RCRA Resource Conservation and Recovery Act
Rl Reconnaissance Inspection
XII
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List of Acronyms
LIST OF ACRONYMS (Continued)
Acronym
Full Phrase
RNC
SARA
SDWA
SIC
SIP
SNC
SNUR
SOUR
SPCC
SS
TCLP
TDDP
TIE
TKN
TME
TRE
TS
TSCA
TSDF
TSS
TVS
UIC
DSC
USDW
USGS
LIST
VEO
VOC
WEF
WENDB
WET
WPCF
WQA
WQS
WWTP
XSI
Reportable Noncompliance
Superfund Amendments and Reauthorization Act
Safe Drinking Water Act
Standard Industrial Classification
State Implementation Plan
Significant Noncompliance
Significant New Use Rule
Specific Oxygen Uptake Rate
Spill Prevention Control and Countermeasure Plan
Suspended Solids
Toxicity Characteristic Leaching Procedure
Treatment, Destruction, and Disposal Facility
Toxicity Identification Evaluation
Total Kjeldahl Nitrogen
Test Marketing Exemption
Toxicity Reduction Evaluation
Total Solids
Toxic Substances Control Act
Treatment, Storage, and Disposal Facility
Total Suspended Solids
Total Volatile Solids
Underground Inspection Control
United States Code
Underground Source of Drinking Water
United States Geological Survey
Underground Storage Tank
Visible Emission Observation
Volatile Organic Compound
Water Environment Federation
Water Enforcement Data Base
Whole Effluent Toxicity
Water Pollution Control Federation
Water Quality Act
Water Quality Standards
Wastewater Treatment Plant
Toxics Sampling Inspection
XIII
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List of Acronyms
*** Mrrrcc ***
NOTES
XIV
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1. INTRODUCTION
Contents Page
A. Purpose and Objectives
Inspection Types 1-1
B. Legal Authority for NPDES Inspections
Inspection Authority 1-7
State Program Authority 1-7
C. Responsibilities of the NPDES Inspector
Legal Responsibilities 1-9
Procedural Responsibilities 1-9
Safety Responsibilities 1-10
Professional Responsibilities 1-11
Quality Assurance Responsibilities 1-12
List of Tables
1-1 Comparison of Inspection Activities With Inspection Types 1-5
1-2 NPDES-Related Statutes and Regulations 1-8
1-3 Inspector's Responsibilities 1-14
Associated Appendices
A EPA Order 1440.2 Health and Safety Requirements for Employees Engaged in Field
Activities
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Chapter One Contents
NOTES
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1. INTRODUCTION
A. Purpose and Objectives
Under 40 Code of Regulations (CFR) 123.26 (relating to State programs), three objectives
should be met during a routine compliance inspection. According to this section, the
inspection should be performed in a manner designed to:
• Determine, compliance status with permit conditions and other program requirements
• Verify the accuracy of information submitted by permittees
• Verify the adequacy of sampling and monitoring conducted by the permittee.
Other purposes of compliance inspections include:
• Gathering evidence to support enforcement actions
• • Obtaining information that supports the permitting process
• Assessing compliance with orders or consent decrees.
Inspection Types
This manual provides guidance applicable to each type of inspection a National Pollutant
Discharge Elimination System (NPDES) inspector may be required to conduct at an NPDES
permitted facility. The different types of inspections are described below.
Compliance Evaluation Inspection (CEI)
The CEI is a nonsampling inspection designed to verify permittee compliance with applicable
permit self-monitoring requirements, effluent limits, and compliance schedules. This
inspection involves records reviews, visual observations, and evaluations of the treatment
facilities, laboratories, effluents, receiving waters, etc. The CEI examines both chemical and
biological self-monitoring and forms the basis for all other inspection types except the
Reconnaissance Inspection.
Compliance Sampling Inspection (CSI)
During the CSI, representative samples required by the permit are obtained. Chemical and
bacteriological analyses are performed, and the results are used to verify the accuracy of the
permittee's self-monitoring program and reports; determine compliance with discharge
limitations; determine the quantity and quality of effluents; develop permits; and provide
1-1
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Chapter One Introduction
evidence for enforcement proceedings where appropriate. In addition, the CSI includes the
same objectives and tasks as a CEI.
Performance Audit Inspection (PAD
The PAI is used to evaluate the permittee's self-monitoring program. As with a CEI, the PAI is
used to verify the permittee's reported data and compliance through a records check.
However, the PAI provides a more resource-intensive review of the permittee's self-monitoring
program and evaluates the permittee's procedures for sample collection, flow measurement,
chain-of-custody, laboratory analyses, data compilation, reporting, and other areas related to
the self-monitoring program. In a CEI, the inspector makes a cursory visual observation of the
treatment facility, laboratory, effluents, and receiving waters. In a PAI, the inspector actually
observes the permittee performing the self-monitoring process from sample collection and flow
measurement through laboratory analyses, data workup, and reporting. The PAI does not
include the collection of samples by the inspector. However, the inspector may require the
permittee to analyze performance samples for laboratory evaluation purposes.
Compliance Biomonitoring Inspection (CBI)
This inspection includes the same objectives and tasks as a CSI. A CBI reviews a permittee's
toxicity bioassay techniques and records maintenance to evaluate compliance with the
biomonitoring terms of the NPDES permit and to determine whether the permittee's effluent is
toxic. The CBI also includes the collection of effluent samples by the inspector to conduct
acute and chronic toxicity testing to evaluate the biological effect of a permittee's effluent
discharge(s) on test organisms.
Toxics Sampling Inspection (XSI)
The XSI has the same objectives as a conventional CSI. However, it places increased
emphasis on toxic substances regulated by the NPDES permit. The XSI covers priority
pollutants other than heavy metals, phenols, and cyanide, which are typically included in a
CSI (if regulated by the NPDES permit). An XSI uses more resources than a CSI because
highly sophisticated techniques are required to sample and analyze toxic pollutants. An XSI
may also evaluate raw materials, process operations, and treatment facilities to identify toxic
substances requiring controls.
Diagnostic Inspection (PI)
The Dl primarily focuses on Publicly Owned Treatment Works (POTWs) that have not
achieved permit compliance. POTWs who are having difficulty diagnosing their problems are
targeted. The purposes of the Dl are to identify the causes of noncompliance, suggest
immediate remedies that will help the POTW achieve compliance, and support current or
future enforcement action. Once the cause of noncompliance is defined, an administrative
1-2
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Chapter One Introduction
order is usually issued that requires the permittee to conduct a detailed analysis and develop
a composite correction plan.
Reconnaissance Inspection (Rl)
The Rl is used to obtain a preliminary overview of a permittee's compliance program. The
inspector performs a brief visual inspection of the permittee's treatment facility, effluents, and
receiving waters. The Rl uses the inspector's experience and judgment to summarize quickly
any potential compliance problems. The objective of the Rl is to expand inspection coverage
without increasing inspection resources. The Rl is the briefest and least resource intensive of
all NPDES inspections.
Pretreatment Compliance Inspection (PCI)
The PCI evaluates the POTW's implementation of its approved pretreatment program. It
includes a review of the POTW's records on monitoring, inspections, and enforcement
activities for its industrial users (IDs). The PCI may be supplemented with ID inspections. An
IU inspection is an inspection of any significant ID that discharges to the POTW. The
inspection can include sampling or not, depending on the reason for the inspection. If
feasible, inspectors should conduct the PCI concurrently with another NPDES inspection of
the POTW. Additional guidance is available in the U.S. Environmental Protection Agency
(EPA) Guidance for Conducting a Pretreatment Compliance Inspection (September, 1991).
It should be noted that a related type of review procedure, the pretreatment audit, is also
performed by Approval Authorities. The pretreatment audit is not treated in depth in this
manual because it is not regarded as a true NPDES compliance inspection. The pretreatment
audit is defined and discussed in Section 1.2, page 1-1, of the U.S. EPA guidance manual
Pretreatment Compliance Inspection and Audit Manual for Approval Authorities (July, 1986)
and the Control Authority Pretreatment Audit Checklist and Instructions (May 1992).
Legal Support Inspection (LSI)
The LSI is a resource intensive inspection conducted when an enforcement problem is
identified as a result of a routine inspection or a complaint. For an LSI, the appropriate
resources are assembled to deal effectively with a specific enforcement problem.
Summary
Table 1-1 matches minimum inspection activities with each of the inspection types. The given
activities are only minimum requirements, and an inspector is not limited to the stated
activities; additional activities may be conducted, depending upon the focus of the inspection.
The inspector should plan all activities and coordinate with compliance personnel before the
inspection. The minimum requirements may serve as a basis for deciding what activities will
be conducted onsite and for determining what additional information is to be gathered or
1-3
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Chapter One Introduction
verified during the inspection. Compliance personnel should choose the type of inspection to
be conducted based on the compliance status of the facility, the information needed from the
facility, and the type of facility involved.
1-4
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Chapter One
Introduction
Table 1-1
Comparison of Inspection Activities With Inspection Types
Activity Description
Pre-lnspection
Review of Facility Background
Development of an Inspection Plan
Notification of the Facility
Entry Onsite
Entry Procedures
Opening Conference
Recordkeeping and Reporting
Permit Information Verification
Evaluation Procedures
Compliance Schedule Status Review
Pretreatment Record Review
Facility Site Review
Physical Inspection
Operation Evaluation
Maintenance Evaluation
Sampling
Evaluation of Permittee Program
Inspector's Compliance Sampling
Flow Measurement
Evaluation of Permittee Flow
Measurement
Verification of Flow Measurements
Biomonitoring
Evaluation of Permittee Self-Monitoring
Program
Compliance Biomonitoring
Laboratory Quality Assurance
Sampling Techniques Evaluation
Analyses Techniques Evaluation
Laboratory Quality Assurance
Inspection Types
CEI
I
O
0
I
c
I
I
I
c
I
c
c
I
-
I
c
c
-
I
c
c
CSI
I
I
0
I
c
I
I
I
O
c
c
c
I
I
I
I
c
-
I
c
c
PAI
I
O
O
I
c
I
I
I
O
c
c
c
I
-
I
c
I
-
I
I
I
CBI
I
I
O
I
c
c
c
-
-
c
c
c
O
I
I
c
I
I
c
c
c
XSI
I
I
O
I
c
I
I
I
O
c
c
c
I
I
I
c
c
-
c
c
c
Dl
I
0
O
I
c
I
I
I
c
I
I
I
I
O
I
I
c
-
c
c
c
Rl
I
0
0
I
c
O
c
I
-
c
c
c
c
-
c
c
-
-
c
c
c
PCI
I
0
O
I
c
O
c
I
I
O
O
-
c
O
O
c
-
-
O
O
O
1-5
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Chapter One
Introduction
Table 1-1
Comparison of Inspection Activities With Inspection Types
(Continued)
Activity Description
Other Site Activities
Inspection of Industrial Discharges to
POTWs
Documentation of Hazardous Waste
Storage and Disposal
Documentation of Air Pollution Releases
Sludge Management Releases
Documentation
Field Notes and Statements
Photographs, Drawings, and Maps
Copies of Facility Records
Closing Procedures
Closing Conference
Notice of Deficiency
Follow-Up
Inspection Form
Narrative Comments/Checklists
Input on PCS
Inspection Types
CEI
-
-
-
I
O
O
I
O
I
I
I
CSI
-
O
O
c
I
c
O
I
O
I
I
I
PAI
-
O
O
c
I
O
O
I
O
I
I
I
CBI
-
O
O
c
I
0
O
I
O
I
I
I
XSI
-
O
O
c
I
O
O
I
O
I
I
I
Dl
-
O
O
c
I
I
I
I
O
I
I
I
Rl
-
O
0
c
I
c
O
I
O
I
I
I
PCI
0
0
0
c
I
O
I
I
O
I
I
I
LEGEND
I - Activity is conducted in an in-depth manner.
C - Activity is conducted in a cursory manner.
O - Activity is optional, but may be recommended by Regional or State policy.
1-6
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1. INTRODUCTION
B. Legal Authority for NPDES
Inspections
The Federal Water Pollution Control Act of 1972, as amended by the Clean Water Act (CWA
or the Act) of 1977 and the Water Quality Act of 1987, gives the Environmental Protection
Agency (EPA) the authority to regulate the discharge of pollutants to waters of the United
States. The Act provides broadly defined authority to establish the NPDES Permit Program,
define pollution control technologies, establish effluent limitations, obtain information through
reporting and compliance inspections, and take enforcement actions (both civil and criminal)
when violations of the Act occur. Table 1-2 provides a listing of applicable NPDES statutes
and regulations.
Inspection Authority
Under Section 402 of the Act, point source dischargers of pollutants (e.g., municipal
wastewater treatment plants, industries, animal feedlots, aquatic animal production facilities,
and mining operations) are issued permits that set specific limits and operating conditions to
be met by the permittee. Section 308 authorizes inspections and monitoring to determine
whether NPDES permit conditions are being met. This section provides for two types of
monitoring:
• Self-monitoring, where the facility must monitor itself
• Monitoring by the permit-issuing agency (EPA or State), a process that may include the
agency's evaluating the self-monitoring and/or conducting its own monitoring.
According to the Act, EPA may conduct an inspection, including storm water, sludge,
combined sewer overflows, and pretreatment, wherever there is an existing NPDES permit.
Inspections may also be conducted where a discharge exists or is likely to exist and no permit
has been issued.
State Program Authority
Much of the compliance with the NPDES program is monitored by the State. Sections 308 and
402 of the Act provide for the transfer of Federal program authority to States to conduct
NPDES permit compliance monitoring. EPA Regional Administrators and some State water
pollution control agencies have signed formal cooperative agreements that ensure timely,
accurate monitoring of compliance with permit conditions. States may implement
requirements and regulations that are more stringent than those under the CWA.
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Chapter One
Introduction
Table 1-2
NPDES-Related Statutes and Regulations
Topic
Reference
Inspection Authority
Self-Monitoring and Recordkeeping Authority
Confidential Information
Emergency Authority
Employee Protection
Permits
EPA Permitting Procedures
Technical Requirements
Best Management Practices (BMP)
Spill Prevention Control and
Countermeasure (SPCC) Plan Waivers
Effluent Guidelines
Pretreatment Standards
Sludge
CWA1
§308
§308
§308(b)
§504
§507
§402
§402
§§301,304,307
§304(e)
§311
§301
§304
§§307, 402
§405
40 CFff
122.41 (i), 123.26
122.41 (h), G), and (I), 122.48
2.201, 2.215, 2.302, 122.7
123.27
122, 123.25
124
129, 133, 136
125
112
125,230
405-471
122.21, 403, and 405-471
60, 61, 123, 258, 501, and
503
1 Clean Water Act
2 Code of Federal Regulations, Revised as of July 1, 1994
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1. INTRODUCTION
C. Responsibilities of the NPDES
Inspector
The primary role of a NPDES inspector is to gather information that can be used to determine
the reliability of the permittee's self-monitoring data and evaluate compliance with permit
conditions, applicable regulations, and other requirements. The NPDES inspector also plays
an important role in enforcement case development and support, and in permit development.
To fulfill these roles, inspectors are required to know and abide by applicable regulations,
permits, policies, and procedures; legal requirements concerning inspections; procedures for
effective inspection and evidence collection; accepted safety practices; and quality assurance
standards.
Legal Responsibilities
Inspectors must conduct all inspection activities within the legal framework established by the
Act, including:
Presenting proper credentials
Properly handling confidential business information.
Inspectors also must be familiar with the conditions of the specific permit and with all
applicable statutes and regulations.
Procedural Responsibilities
Inspectors must be familiar with general inspection procedures and evidence collection
techniques to ensure adequate inspections and to avoid endangering potential legal
proceedings on procedural grounds.
Inspection Procedures
Inspectors should observe standard procedures for conducting each inspection element. The
elements of the inspection process listed in Table 1-3 are common to most NPDES
compliance inspections. They are grouped by the major inspection activities:
• Pre-lnspection Preparation
• Entry
• Opening Conference
• Facility Inspection
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Chapter One Introduction
• Closing Conference
• Inspection Report.
While the emphasis given to each element may vary among facilities, the inspector's
procedural responsibilities remain as listed.
Evidence Collection
Inspectors must be familiar with general evidence-gathering techniques. Because the
Government's case in a civil, criminal, or administrative prosecution depends on the evidence
they have gathered, inspectors must keep detailed records of each inspection. These data will
be used for preparing the inspection report, determining the appropriate enforcement
response, and giving testimony in an enforcement case.
In particular, inspectors must know how to:
• Substantiate facts with items of evidence, including samples, photographs, document
copies, statements from witnesses, and personal observations
• Evaluate what evidence is necessary (routine inspections)
• Abide by chain-of-custody procedures
• Collect and preserve evidence in a manner that will be incontestable in legal
proceedings
• Write clear, objective, and informative inspection reports
• Testify in court and administrative hearings.
Inspection procedures are discussed in detail in Chapter Two of this manual.
Safety Responsibilities
The inspection of wastewater and other environmental pollution control facilities always poses
a certain degree of health and safety risk. To avoid unnecessary risks, the inspector should be
familiar with alt safety obligations and practices, including Regional or State policy and
requirements. The safety equipment and procedures required for a facility will be based on
either standard safety procedures or the response to the 308 (inspection notification) Letter.
Inspectors should do the following:
• Use safety equipment in accordance with available guidance and labeling instructions.
• Maintain safety equipment in good condition and proper working order.
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Chapter One Introduction
• Dress appropriately for the particular activity and wear appropriate protective clothing.
For example, gloves should be worn during sample collection to protect the inspector
and to prevent the potential for sample contamination.
• Use any safety equipment customary in the establishment being inspected (e.g., hard
hat or safety glasses).
• Never enter confined spaces unless properly trained, equipped, and permitted (if
applicable).
For any safety-related questions not covered in this manual, consult the current approved
safety manual for greater detail. Appendix A contains EPA's Order 1440.2, Health and Safety
Requirements for Employees Engaged in Field Activities.
Professional Responsibilities
Inspectors are expected to perform their duties with the highest degree of professionalism.
Procedures and requirements ensuring ethical actions have been established through many
years of Government inspection experience. The procedures and standards of conduct listed
below have evolved for the protection of the individual and EPA, as well as industry.
• All inspections are to be conducted within the framework of the United States *
Constitution and with due regard for individual rights regardless of race, sex, creed, or
national origin.
• Inspectors are to conduct themselves at all times in accordance with the regulations
prescribing employee responsibilities and conduct.
• The facts of an inspection are to be noted and reported completely, accurately, and
objectively.
• In the course of an inspection, any act or failure to act motivated by reason of private
gain is illegal. Actions that could be construed as such should be scrupulously avoided.
• A continuing effort should be made to improve professional knowledge and technical
skill in the inspection field.
Professional Attitude
The inspector is a representative of EPA and is often the initial or only contact between EPA
and the permittees. In dealing with facility representatives and employees, inspectors must be
professional, tactful, courteous, and diplomatic. A firm but responsive attitude will encourage
cooperation and initiate good working relations. Inspectors should not speak derogatorily of
any product, manufacturer, or person.
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Chapter One Introduction
Attire
Inspectors should dress appropriately, including wearing protective clothing or equipment, for
the activity in which they are engaged.
Gifts, Favors, Luncheons
Inspectors should not accept favors, benefits, or job offers under circumstances that might be
construed as influencing the performance of governmental duties. If offered a bribe, the
inspector should:
• Ask what the offer is for
• Explain, if the offer is repeated, that both parties to such transactions may be guilty of
violating Federal statutes
• Not accept any money or goods
• Report the incident in detail to supervisor.
Employees are not authorized to accept business luncheons; they must pick up their own
checks. (See page 20, U.S. EPA Guidance on Ethics and Conflict of Interest, February 1984,
and 5 CFR 2635, Standards of Ethical Conduct for Employees of the Executive Branch,
August 7, 1992.) If ethics issues arise, the inspector should contact the proper EPA or State
official.
Requests for Information
EPA has an "open-door" policy on releasing information to the public. This policy is to make
information concerning EPA and its work freely and equally available to all interested
individuals, groups, and organizations. In fact, EPA employees have both a legal and
traditional responsibility for making useful educational and safety information available to the
public. This policy, however, does not extend to information about a suspected violation,
evidence of possible misconduct, or confidential business information. The disclosure of
information is discussed further in Chapter Two, Disclosure of Official Information.
Quality Assurance Responsibilities
The inspector must assume primary responsibility for ensuring the quality and accuracy of
compliance inspection and analytical data. While other organizational elements play an
important role in quality assurance, it is the inspector who must ensure that all data introduced
into an inspection file are complete, accurate, and representative of existing conditions. To
help the inspector meet this responsibility, Regional Offices have established quality
assurance plans that identify individual responsibilities and document detailed procedures.
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Chapter One Introduction
The objective of a quality assurance plan is to establish standards that will guarantee that
inspection and analytical data meet the requirements of all users. Many elements of quality
assurance plans are incorporated directly into the basic inspection procedures and may not be
specifically identified as quality assurance techniques.
The inspector must be aware that following established inspection procedures is critical to the
inspection program. These procedures have been developed to reflect the following quality
assurance elements:
• Valid data collection
• Approved standard methods
• Control of service, equipment, and supplies
• Standard data handling and reporting.
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Chapter One Introduction
Table 1-3
Inspector's Responsibilities
Pre-lnspection Preparation. Ensure effective use of inspection resources.
• Notify facility, if applicable.
• Establish purpose and scope of inspection.
• Review background information and EPA records, including permit and permittee
compliance file.
• Contact appropriate staff personnel responsible for the permittee: compliance
personnel, pretreatment coordinator, etc.
• Develop plan for inspection.
• Prepare documents and equipment, including appropriate safety equipment.
• Coordinate schedule with laboratory if samples are to be collected.
• Coordinate schedule with other appropriate regulatory authorities.
• Contact party responsible for sample transportation, for packing/shipping
requirements.
Entry. Establish legal entry to facility.
• Present official credentials.
• Manage denial of entry if necessary.
Opening Conference. Orient facility officials to inspection plan.
• Discuss inspection objectives and scope.
• Establish working relationship with facility officials.
Facility Inspection. Determine compliance with permit conditions; collect evidence of
violations.
Conduct visual inspection of facility.
Review facility records.
Inspect monitoring location, equipment, and operations.
Collect samples, if appropriate.
Review laboratory records for QA/QC.
Review laboratory procedures to verify use of approved methods.
Document inspection activities.
Closing Conference. Conclude inspection.
Collect missing or additional information.
Clarify questions with facility officials.
Prepare necessary receipts.
Review inspection findings and inform officials of follow-up procedures.
Issue deficiency notice, if appropriate.
Inspection Report. Organize inspection findings in a report so as to be useful in the
development and support of evidence for potential enforcement action.
• Complete NPDES Compliance Inspection Report Form 3560.
• Prepare narrative report, checklists, and documentary information as appropriate.
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2. INSPECTION PROCEDURES
Contents Page
A. Pre-lnspection Preparation
Review of Facility Background Information 2-1
Sources of Facility Background Information 2-4
Development of an Inspection Plan 2-5
Notification of the Facility 2-6
State Notification of Federal Inspection 2-6
Preparation of Equipment and Supplies 2-6
B. Ent
Entry Procedures 2-9
Problems With Entry or Consent 2-11
Warrants 2-12
C. Opening Conference
Considerations 2-13
D. Documentation
Inspector's Field Notebook 2-17
Samples 2-18
Statements 2-18
Photographs 2-19
Videotapes 2-21
Drawings and Maps 2-21
Printed Matter 2-21
Mechanical Recordings 2-22
Copies of Records 2-22
General Considerations 2-23
Confidential Information 2-24
E. Closing Conference
Precautions and Guidelines 2-27
Deficiency Notice 2-27
F. Inspection Report
Objective of the NPDES Inspection Report 2-29
Elements of a Report 2-29
The Permit Compliance System (PCS) 2-31
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Chapter Two Contents
List of Tables
2-1 List of Field Sampling Equipment 2-8
Associated Appendices
B Sample Section 308 Letter
C EPA's Memorandum on Entry Procedures
D EPA's Memorandum on Deficiency Notice Guidance
E NPDES Compliance Inspection Report Form
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2. INSPECTION PROCEDURES
A. Pre-lnspection Preparation
Pre-planning is necessary to ensure that the inspection is focused properly and is conducted
smoothly and efficiently. It involves:
Review of facility background information
Development of an inspection plan
Notification of the facility, if applicable
State notification of Federal inspection
Equipment preparation.
Review of Facility Background Information
Collection and analysis of available background information on the candidate facility are
essential to the effective planning and overall success of a compliance inspection. Materials
obtained from files of Federal, State, and local agencies, technical libraries, and other
information sources will enable inspectors to familiarize themselves with facility operations;
conduct a timely inspection; minimize inconvenience to the facility by not requesting data
previously provided to the Federal, State, and/or local agencies; conduct a thorough and
efficient inspection; clarify technical and legal issues before entry; and develop a sound and
factual inspection report. The types of information that may be available for review are listed
below. The inspector must determine the amount of background information necessary for the
inspection and in collecting this information, should focus on the characteristics unique to the
permittee: design, historical practices, legal requirements, etc.
General Facility Information
• Maps showing facility location, plumbing including wastewater discharge pipes,
sampling points, overflow and bypass points, and geographic features
• Plant layout and process flow diagram
• Names, titles, and telephone numbers of responsible facility officials
• Any special entry requirements
• Any safety requirements
• Description of processing operations and wastewater discharges
• Production levels—past, present, and future
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Chapter Two Inspection Procedures
• Hydrological data
• Geology/hydrogeology of the area
• Changes in facility conditions since previous inspection/permit application
• Available aerial photographs.
Requirements, Regulations, and Limitations
• Copies of Federal, State, and local existing permits, regulations, and requirements and
restrictions placed on permittee discharges in the form of standards and compliance
schedules
• Monitoring and reporting requirements and available monitoring stations
• Special exemptions and waivers, if any
• Receiving stream water quality standards
• Information concerning sludge, air, solid, and hazardous waste treatment and disposal.
Facility Compliance and Enforcement History
• Previous inspection reports
• Correspondence among facility, local, State, and Federal agencies
• Complaints and reports, follow-up studies, findings, and remedial action
• Documentation on past compliance violations, exceedences, status of requested
regulatory corrective action, if any
• Enforcement actions such as compliance schedules and consent orders
• Status of current and pending litigation against facility
• Self-monitoring data and reports
• Previous Environmental Protection Agency (EPA), State, or consultant studies and
reports
• Previous deficiency notices issued to facility
• Laboratory capabilities and analytical methods used by the facility
• Name(s) of contract laboratories, if applicable
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Chapter Two Inspection Procedures
Previous Discharge Monitoring Report (DMR)—Quality Assurance (QA) files and
reports
Permit Compliance System (PCS) information
Reports from special studies (e.g., stream monitoring, internal audits) or compliance
schedules.
Pollution Control and Treatment Systems
• Description and design data for pollution control system and process operation, if
available
• Sources and characterization of discharge
• Type and amount of wastes discharged
• Spill prevention contingency plans, if available
• Available bypasses or diversions and spill containment facilities
• Pollution control units, treatment methods, and monitoring systems.
Pretreatment Information
• Information concerning compliance schedule to install technologies (industrial facilities)
or develop a pretreatment program (Publicly Owned Treatment Works [POTWs])
• Pretreatment reports as required by the General Pretreatment Regulations, regional,
State, or local requirements
• The POTW's enforcement response plan and sewer use ordinance, including local
discharge limits
• Information concerning industrial discharges to POTWs, such as:
- Industrial monitoring and reporting requirements
- POTW monitoring and inspection program
- Waste contribution to the POTW
- Compliance status of industry with pretreatment requirements
- POTW enforcement initiatives.
Chapter 9 of this manual discusses pretreatment program requirements in greater detail.
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Chapter Two Inspection Procedures
Sources of Facility Background Information
Previous Inspections
Previous inspection reports can provide general facility information, as well as problems or
concerns noted in previous inspections. Inspectors who have visited the facility for National
Pollutant Discharge Elimination System (NPDES), pretreatment, or other regulatory programs
may also provide information on the facility.
Laws and Regulations
The Clean Water Act (CWA) and related NPDES regulations establish procedures, controls,
and other requirements applicable to a facility. In addition, State laws and regulations, and
sometimes even local ordinances, are applicable to the same facility. Refer to Table 1 -2 for a
list of applicable NPDES-related statutes and regulations.
Permits and Permit Applications
Permits provide information on the limitations, requirements, and restrictions applicable to
discharges; compliance schedules; and monitoring, analytical, and reporting requirements.
Permit applications provide technical information on facility size, layout, and location of
pollutant sources; treatment and control practices; contingency plans and emergency
procedures; and pollutant characterization—types, amounts, applicability of effluent guidelines,
and points/locations of discharge. Permit applications for air, solid, and hazardous waste
treatment and disposal permits may provide additional information to the inspector that is not
available elsewhere.
Regional and State Files and Personnel
Files or Regional and State personnel often can provide correspondence; facility self-
monitoring data; inspection, Quarterly Noncompliance Report (QNCR), and DMR QA reports;.
and permits and permit applications applicable to individual facilities. They can provide
compliance, enforcement, and litigation history; special exemptions and waivers applied for
and granted or denied; citizen complaints and action taken; process operational problems/
solutions; pollution problems/solutions; laboratory capabilities or inabilities; and other proposed
or historical remedial actions. This information can provide design and operation data,
recommendations for process controls, identification of pollutant sources, treatment/control
systems improvement, and remedial measures.
Technical Reports. Documents, and References
These information sources provide generic information on waste loads and characterization,
industrial process operations, and pertinent specific data on available treatment/control
techniques, such as their advantages or disadvantages and limits of application and pollutant
removal efficiencies. Such sources include Development Documents for Effluent Standards
and Guidelines.
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Chapter Two Inspection Procedures
Other Statutory Requirements
Facility files maintained by EPA and the State pursuant to other statutes (e.g., Toxic
Substances Control Act [TSCA]; Resource Conservation and Recovery Act [RCRA];
Comprehensive Environmental Response, Compensation and Liability Act [CERCLA]; Federal
Insecticide, Fungicide and Rodenticide Act [FIFRA]; Clean Air Act [CAA]) may also contain
information useful to the NPDES inspection.
Development of an Inspection Plan
Plans are helpful tools in organizing and conducting compliance inspections. A plan is,
therefore, recommended to effectively conduct a compliance inspection. After reviewing the
available background information, the inspector prepares a comprehensive plan to define
inspection objectives, tasks and procedures, resources required to fulfill the objectives,
inspection schedule, and when findings and conclusions on the work will be reported. At least
the following items need to be considered:
• Objectives
- What is the purpose of the inspection?
- What is to be accomplished?
• Tasks
- What tasks are to be conducted?
- What information must be collected?
- What records will be reviewed?
• Procedures
- What procedures are to be used?
- Will the inspection require special procedures?
• Resources
- What personnel will be required?
- What equipment will be required?
• Schedule
- What will be the time requirements and order of inspection activities?
- What will be the milestones?
• Coordination
- What coordination with laboratories or other regulatory agencies will be required?
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Chapter Two Inspection Procedures
An outline of tentative inspection objectives, meetings to be held, and records that will be
reviewed can be prepared and presented to the facility officials during the opening conference.
Notification of the Facility
With regard to the EPA-administered NPDES program, the permittee is sometimes notified by
a Section 308 Letter or "308 Letter" that the facility is scheduled for an inspection. (Appendix
B is an example of a typical 308 Letter.) The signature authority for a 308 Letter may be
delegated to a section chief. The 308 Letter advises the permittee that an inspection is
imminent and usually requests information regarding on-site safety regulations to avoid
problems concerning safety equipment at the time of inspection. The inspector may wish to
facilitate the inspection process by suggesting that the permittee send general information to
the inspector before the site visit. This information may include such items as names,
addresses, and updated process information. The 308 Letter may specify the exact date of
inspection, if coordination with the permittee is required. The 308 Letter also is used to inform
the permittee of the right to assert a claim of confidentiality. Depending on the type of
inspection, the permittee may be notified by telephone that an inspection is imminent.
However, inspections are usually done without any pre-notification of the exact date.
Notification is not recommended when illegal discharges or emissions or improper records are
suspected. The concern that physical conditions may be altered before the inspection or that
records will be destroyed justifies an unannounced inspection. A written notification including
information on the right to assert a claim of confidentiality can be presented at the time of the
unannounced inspection.
State Notification of Federal Inspection
The inspector must be certain that the appropriate State regulatory agency is notified in a
timely manner of inspections to be conducted in its jurisdiction. The State should be notified
of all Federal inspections unless disclosing inspection information would jeopardize an
unannounced inspection.
Preparation of Equipment and Supplies
If sampling is to be performed, part of the pre-inspection process involves obtaining and
preparing sampling equipment. The type of equipment may vary according to the facility
inspected and the type of inspection. Table 2-1 includes a list of field sampling equipment
that may be needed. All equipment must be checked, calibrated, and tested before use. The
inspector also must ensure that all materials necessary to complete an inspection are taken to
the inspection site. The inspector is responsible for maintaining the equipment properly, in
accordance with operating instructions.
Safety equipment and procedures required for a facility will be based on the response to the
notification or 308 Letter and standard safety procedures. Safety requirements must be met,
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Chapter Two Inspection Procedures
not only for safety reasons, but to ensure that the inspector is not denied entry to the facility
or parts of it.
Photocopies of appropriate checklists to be used during the inspection should be obtained
during the pre-inspection preparation.
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Chapter Two
Inspection Procedures
Table 2-1
List of Field Sampling Equipment
Field Equipment
Documents and Recordkeeping Tools
File
• Checklists
• Log book
• Shipping labels
• Analysis request forms
• Waterproof pen
• Calculator
Sampling Materials
• Automatic samplers
• Tubing
• Sample containers, including extras
• Batteries
• Desiccant
• Sample bottle labels/sample seals
• Plastic security tape
• Chain-of-custody forms
• Dissolved oxygen meters
• pH meter
• TRC meter
• pH buffer
• Deionized water
• Chart paper
• Thermometer
• Coolers/ice
• Preservatives
Sample Transportation Materials
• Bubble pack material
• Filament tape
• Airbill/bill of lading
Flow Measurement Devices
• Measurement devices (e.g., flumes,
weirs, portable ultrasound or bubble
systems)
• Flow discharge tables
• Level
Ruler
• Stopwatch or watch with second
hand
Protective Clothing
Hard hat
• Hearing protection
• Safety shoes
• Gloves
• Coveralls
• Reflective safety vest
• Safety glasses/goggles
• Rainwear
Safety Equipment
• First-aid kit
• Meters (oxygen content, explosivity,
and toxic gas
• Safety harness and retrieval system
• Ventilation equipment
• Respirator
• Filter cartridges
• Self-contained breathing apparatus (if
appropriate)
Tools
Multi-tooled jack knife (Swiss Army type)
Electrical and duct tape
Tape measure
Hand-held range finder and level
Camera/film
Flashlight
Screwdriver
Adjustable wrench and vise grips
Bucket (plastic or stainless steel, as
appropriate)
Nylon cord
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2. INSPECTION PROCEDURES
B. Entry
Entry Procedures
Authority
The basic authority for entry into a wastewater facility is §308(a)(4)(B) of the CWA which
states:
the Administrator or his authorized representative, upon presentation of his
credentials shall have a right of entry to, upon, or through any premises in which an
effluent source is located or in which any records are required to be maintained . . .
and may at reasonable times have access to and copy any records, inspect any
monitoring equipment or method . . . and sample any effluents which the owner or
operator of such source is required to sample.
In addition, NPDES permits contain inspection authority provisions.
Arrival
Arrival at the facility and the facility inspection should occur during normal working hours. The
facility owner or agent in charge should be located as soon as the inspector arrives on the
premises. Prior to entering a facility, inspectors should observe it as thoroughly as possible
from public grounds.
Credentials
When the proper facility officials have been located, the inspector must introduce himself or
herself as an EPA/State inspector and present the proper EPA/State credentials. These
credentials indicate that the holder is a lawful representative of the regulatory agency and is
authorized to perform NPDES inspections. The credentials must be presented whether or not
identification is requested.
After facility officials have reviewed the credentials, the officials may telephone the appropriate
State or EPA Regional Office for verification of the inspector's identification. Credentials
should never leave the sight of the inspector.
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Chapter Two Inspection Procedures
Consent
Consent to inspect the premises must be given by the owner or operator at the time of the
inspection. As long as the inspector is allowed to enter, entry is considered voluntary and
consensual, unless the inspector is expressly told to leave the premises. Expressed consent
is not necessary; absence of an expressed denial constitutes consent.
Reluctance to Give Consent. The receptiveness of facility officials toward inspectors is likely
to vary among facilities. Most inspections will proceed without difficulty. If consent to enter is
flatly denied, the inspector should follow denial of entry procedures. In other cases, officials
may be reluctant to give entry consent because of misunderstood responsibilities,
inconvenience to a firm's schedule, or other reasons that may be overcome by diplomacy and
discussion.
Whenever there is a difficulty in gaining consent to enter, inspectors should tactfully probe the
reasons and work with officials to overcome the problems. Care should be taken, however, to
avoid threats of any kind, inflammatory discussions, or deepening of misunderstandings. If
the situation is beyond the authority or ability of the inspector to manage, the regulatory office
should be contacted for guidance.
Claims of Confidentiality
The inspector should explain the permittee's right to claim material as confidential and that the
inspector may examine areas related to effluent production or storage even if the permittee
has asserted claims of confidentiality. Confidential information is discussed in greater detail
later in this chapter.
Uncredentialed Persons Accompanying an Inspector. The consent of the owner or agent in
charge must be obtained for persons accompanying an inspector to enter a site if they do not
have specific authorization. If consent is not given, these persons may not enter the
premises. If consent is given, they may not view confidential business information unless
officially authorized for access.
Waivers, Releases, and Sign-In Logs
When the facility provides a blank sign-in sheet, log, or visitor register, it is acceptable for
inspectors to sign it. However, EPA employees must not sign any type of "waiver" or "visitor
release" that would relieve the facility of responsibility for injury or that would limit the rights of
EPA to use data obtained from the facility. The inspector must not agree to any such
unwarranted, restrictive conditions.
If such a waiver or release is presented, the inspectors should politely explain that they cannot
sign and request a blank sign-in sheet. If the inspectors are refused entry because they do
not sign the release, they should leave and immediately report all pertinent facts to the
appropriate supervisory and/or legal staff. All events surrounding the refused entry should be
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Chapter Two Inspection Procedures
fully documented. Problems should be discussed cordially and professionally. Facility officials
must not be subjected to intimidation by the Federal/State inspectors.
Problems With Entry or Consent
Because inspections may be considered adversarial proceedings, the legal authority,
techniques, and competency of inspectors may be challenged. Facility officials also may
display antagonism toward EPA personnel. In all cases, inspectors must cordially explain the
authorities and reasons for the protocols followed. If explanations are not satisfactory or
disagreements cannot be resolved, the inspectors should leave and obtain further direction
from the appropriate EPA supervisory or legal staff. Professionalism and politeness must
prevail at all times. Appendix C contains EPA's Memorandum on Entry Procedures.
Denial of Entry
If an inspector is refused entry into a facility for the purpose of an inspection under the CWA,
certain procedural steps must be followed. The procedures have been developed in
accordance with the 1978 U.S. Supreme Court decision in Marshal v. Barlow's, Inc.
• Ensure that all credentials and notices are presented properly to the facility owner or
agent in charge.
• If entry is not granted, ask why. Tactfully probe the reason for the denial to see if
obstacles (such as misunderstandings) can be cleared. If resolution is beyond the
authority of the inspector, he or she may suggest that the officials seek advice from
their attorneys to clarify EPA's inspection authority under Section 308 of the CWA.
• If entry is still denied, the inspector should withdraw from the premises and contact his
or her supervisor. The supervisor will confer with attorneys to discuss the desirability
of obtaining an administrative warrant.
• All observations pertaining to the denial are to be carefully noted in the field notebook
and inspection report. Include such information as the facility name and exact
address, name and title of person(s) approached, authority of person(s) who refused
entry, date and time of denial, detailed reasons for denial, facility appearance, and any
reasonable suspicions that refusal was based on a desire to cover up regulatory
violations. All such information will be important should a warrant be sought.
Important Considerations
• Under no circumstances should the inspector discuss potential penalties or do anything
that may be construed as coercive or threatening.
• Inspectors should use discretion and avoid potentially threatening or inflammatory
situations. If a threatening confrontation occurs, the inspector should document it and
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then report it immediately to the staff attorney. If feasible, statements from witnesses
should be obtained and included in the documentation.
Withdrawal of Consent During Inspection
If the facility representative asks the inspector to leave the premises after the inspection has
begun, the inspector should leave as quickly as possible following the procedures discussed
previously for denial of entry. All activities and evidence obtained before the withdrawal of
consent are valid. The inspector should ensure that all personal and government equipment
is removed from the facility.
Denial of Access to Some Areas of the Facility
If, during the course of the .inspection, access to some parts of the facility is denied, the
inspector should make a notation of the circumstances surrounding the denial of access and
of the portion of the inspection that could not be completed. He or she then should proceed
with the rest of the inspection. After leaving the facility, the inspector should contact his or her
supervisor and staff attorney at the Regional Office to determine whether a warrant should be
obtained to complete the inspection.
Warrants
The inspector may be instructed by EPA attorneys, under certain circumstances, to conduct
an inspection under search warrant. A warrant is a judicial authorization for appropriate
persons to enter specifically described locations to inspect specific functions. A pre-inspection
warrant possibly could be obtained where there is reason to believe that entry will be denied
when the inspector arrives at the facility or when the inspector anticipates violations that could
be hidden during the time required to obtain a search warrant.
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2. INSPECTION PROCEDURES
C. Opening Conference
Once credentials have been presented and legal entry has been established, the inspector
can proceed to outline inspection plans with facility officials. At the opening conference, the
inspector provides names of the inspectors, the purpose of the inspection, authorities under
which the inspection is being conducted, and procedures to be followed. EPA encourages
cooperation between the inspectors and the facility officials in order to facilitate assignments
and ensure the success of the inspection.
Considerations
Inspection Objectives
An outline of inspection objectives will inform facility officials of the purpose and scope of the
inspection and may help avoid misunderstandings.
Order of Inspection
A discussion of the order in which the inspection will be conducted will help eliminate wasted
time by allowing officials time to make records available and start up intermittent operations.
Meeting Schedules
A schedule of meetings with key personnel will allow facility officials adequate time to spend
with the inspector.
List of Records
A list of facility records that will need to be reviewed as part of the inspection should be
provided to facility officials. This will allow the officials adequate time to gather the records
and make them available for the inspector.
Accompaniment
It is important that a facility official accompany the inspector during the inspection not only to
answer questions and describe the plant and its principal operating characteristics, but also for
safety and liability considerations. Discussion of such needs with facility officials will provide
them the opportunity to allocate personnel for this purpose. It is also advisable that the
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inspector talk to the personnel actually responsible for performing sample collection and
analysis to gather specific information on these procedures.
Permit Verification
The inspector should verify pertinent information included in the permit, such as facility name
and address, receiving waters, and discharge points.
Safety Requirements
The inspector should reaffirm which Occupational Safety and Health Administration (OSHA)
and facility safety regulations will be involved in the inspection and should determine whether
preparations were adequate.
Closing Conference
A post-inspection meeting should be scheduled with appropriate officials to provide a final
opportunity to gather information, answer questions, present findings and deficiencies, and
complete administrative duties.
New Requirements
The inspector should discuss and answer questions pertaining to any new rules and
regulations that might affect the facility. If the inspector is aware of proposed rules that might
affect the facility, he or she may wish to encourage facility officials to obtain a copy.
Split Samples
Facility officials should be informed during the opening conference of their right to receive a
split or duplicate of any physical sample collected for laboratory analysis if sufficient sample
volume is collected. Officials should indicate at this point their desire to receive split and
duplicate samples so that arrangements can be made to secure the samples during
inspection.
Photographs
Photographs can be used to prepare a more thorough and accurate inspection report, as
evidence in enforcement proceedings, and to explain better conditions found at the plant. The
facility officials, however, may object to the use of cameras on their property. If a mutually
acceptable solution cannot be reached and photographs are considered essential to the
inspection, EPA supervisory and legal staff should be contacted for advice.
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Facility personnel also may request that any photographs taken during the visit be considered
confidential. EPA is obliged to comply with this request pending further legal determination.
Facility officials may refuse permission to take photographs unless they can see the finished
print. Self-developing film, although of lower quality, is useful in certain situations. Duplicate
photographs (one for the inspector and the other for the facility) should also satisfy this need.
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*** KirtTEC ***
NOTES
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2. INSPECTION PROCEDURES
D. Documentation
Providing strong documentary support of discrepancies discovered in an inspection is an
inspector's basic responsibility. Documentation serves to "freeze" the actual conditions
existing at the time of inspection so that evidence can be examined objectively by compliance
personnel.
Documentation is a general term referring to all printed information and mechanical media
produced, copied, or taken by an inspector to provide evidence of suspected violations. Some
types are the field notebook, statements, photographs, videotapes, drawings, maps, printed
matter, mechanical recordings, and copies of records.
Inspector's Field Notebook
The core of all documentation relating to an inspection is the field notebook, which provides
accurate and inclusive documentation of all inspection activities. A bound notebook should be
used, and entries should be made in permanent ink. The notebook will form the basis for
written reports and should contain only facts and pertinent observations.
The date and time of arrivals and departures should be noted each day. Language should be
objective, factual, and free of personal feelings or terminology that might prove inappropriate.
Any errors in the notebook should be crossed out and initialed. The field notebook should
never leave the inspector's possession during the inspection, and a facility should generally
not be allowed to copy the field notebook. Notebooks become an important part of the
evidence package and can be entered in court. The field notebook is a part of EPA's files
and is not to be considered the inspector's personal record. Notebooks are held indefinitely
pending disposition instructions.
Inspection Notes
Since an inspector may be called to testify in an enforcement proceeding, it is imperative that
each inspector keep detailed records of inspections, investigations, samples collected, and
related inspection functions. Types of information that should be entered into the field
notebook include the following:
Observations. All conditions, practices, and other observations that will be useful in preparing
the inspection report or that will validate evidence should be recorded.
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Documents and Photographs. All documents taken or prepared by the inspector such as the
completed checklists for the inspection report should be noted and related to specific
inspection activities. (Photographs taken at a sampling site should be listed and described.)
Unusual Conditions and Problems. Unusual conditions and problems should be noted and
described in detail.
General Information. Names and titles of facility personnel and the activities they perform
should be listed along with statements they have made and other general information.
Weather conditions should be recorded. Information about a facility's recordkeeping
procedures may also be useful in later inspections.
Samples
For the analysis of a sample to be admissible as evidence, a logical and documented
connection must be shown between samples taken and analytical results reported. This
connection is shown by using a chain-of-custody system that identifies and accompanies a
sample between the time it is collected and the time it is analyzed. Sampling techniques and
procedures are discussed in detail in Chapter Five, "Sampling."
Statements
Inspectors can attempt to obtain a formal statement from a person who has personal,
firsthand knowledge of facts pertinent to a potential violation. This statement of facts is signed
and dated by the person who can testify to the facts in court, and it may be admissible as
evidence.
The principal objective of obtaining a statement is to record in writing, clearly and concisely,
relevant factual information so that it can be used to document an alleged violation.
Procedures and Considerations
• Determine the need for a statement. Will it provide useful information? Is the person
making the statement qualified to do so by personal knowledge?
• Ascertain all the facts. Make sure all information is-factual and firsthand. Record
those that are relevant and that the person can verify in court. Avoid taking statements
that cannot be personally verified.
• In preparing a statement, use simple narrative style; avoid stilted language.
- Narrate the facts in the words of the person making the statement.
- Use the first-person singular ("I am manager of. . .").
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- Present the facts in chronological order (unless the situation calls for another
arrangement).
Positively identify the person making the statement (name, address, position).
Show why the person is qualified to make the statement.
Present the pertinent facts.
Have the person read the statement and make any necessary corrections before
signing. If necessary, read the statement to the person in the presence of a witness.
- All mistakes that are corrected must be initialed by the person making the
statement.
Ask the person making the statement to write a brief concluding paragraph indicating
that he or she read and understood the statement. This safeguard will counter a later
claim that the person did not know what he or she was signing.
Have the person making the statement sign it.
If he or she refuses to sign the statement, elicit an acknowledgment that it is true and
correct. Ask for a statement in his or her own hand ("I have read this statement and it
is true, but I am not signing it because . . ."). Failing that, declare at the bottom of the
statement that the facts were recorded as revealed and that the person read the
statement and avowed it to be true. Attempt to have any witness to the statement sign
the statement including the witness' name and address.
Provide a copy of the statement to the signer if requested.
Photographs
The documentary value of photographs ranks high as admissible evidence. Clear
photographs of relevant subjects provide an objective record of conditions at the time of
inspection. If possible, keep "sensitive" operations out of the photographed background.
Photographs showing confidential operations or information must be handled as confidential
information.
When a situation dictates the use of photographs, the inspector should obtain the permittee's
approval before taking them. The inspector should be tactful in handling any concerns or
objections a permittee may have about the use of a camera. In some cases, the inspector
may explain to the permittee's representative that wastestreams, receiving waters, and
wastewater treatment facilities are public information, not trade secrets. In the event the
permittee's representative still refuses to allow photographs and the inspector believes the
photographs will have a substantial impact on future enforcement proceedings, Regional
enforcement attorneys should be consulted for further instructions.
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At all times, the inspector is to avoid confrontations that might jeopardize the completion of the
inspection. (Photographs always may be taken from areas of public access [e.g., across a
stream, from a parking lot].)
Equipment
A single-lens reflex camera should be used whenever one is available. This type of camera
will take high-quality photographs, enable the inspector to use a variety of film speeds, and
allow the use of appropriate lenses. Fully automatic 35-mm and pocket cameras can also be
used for routine inspections to record the conditions of the facility during the inspection.
All photographs should be made with color print film because additional equipment, such as a
projector and screen, is not needed to review them. Also, the negatives from color print film
are easily duplicated and the prints can be enlarged and distributed as needed.
Scale, Location, and Direction
It is sometimes useful to photograph a subject from a point that will indicate the location and
direction of the subject. The inclusion in the photograph of an object of known size (e.g., a
person or an auto) will help indicate the approximate size of the subject.
In areas where there is a danger of explosion, flash photographs should not be taken. If there
is a danger of electrical shock, photographs should be taken from a distance known to be
safe.
Documentation
Photographs taken during an inspection are used to supplement the testimony of the inspector
as a witness during a court proceeding. The photographs are not intended to refute testimony
but rather to aid the witness in recalling actual conditions on-site.
A photographic log should be maintained in the inspector's field notebook for all photographs
taken during an inspection; the entries should be made at the time the photograph is taken.
These entries are to be numerically identified so that, after the film is developed, the prints can
be serially numbered to correspond with the logbook descriptions and, if necessary, pertinent
information can be easily transferred to the back of the photograph. The log entries should
include:
• Name and signature of the photographer and witness
• Time of day, weather conditions
• Date
• Location
• Brief description of each subject being photographed.
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Date-back cameras that place the date and time on the photograph are useful. Some Regions
use special stick-on labels to document photographs. These are useful only if they are
prepared objectively and are completely filled in.
Videotapes
Videotapes can provide an objective means of documenting subjects of interest in an
inspection. As with any photographed site or equipment, permission from the permittee to
produce a videotape should be obtained, and the same precautions as those for photographs
(previous section) should be taken for sensitive material. Additionally, sound videos can be
produced, whereby a narrative to the tape can quickly record much of the information needed
to complete an inspection report. As with written notes, the narrative description should be
neutral and should not include personal comments or opinions. Written notes should be
prepared during the site visit as a backup to the videotape in case mechanical problems occur
with the recording. If necessary, color photographs can be made later by stopping the
televised video at frames of interest and photographing the picture.
Drawings and Maps
Schematic drawings, maps, charts, and other graphic records can be useful in supporting
violation documentation. They can provide graphic clarification of site location relative to the
overall facility, relative height and size of objects, and other information which, in combination
with samples, photographs, and other documentation, can produce an accurate, complete
evidence package.
Drawings and maps should be simple and free of extraneous details. Basic measurements
and compass points should be included to provide a scale for interpretation. Drawings and
maps should be identified by source and inspector's initials and should be dated.
Printed Matter
Brochures, literature, labels, and other printed matter may provide important information
regarding a facility's conditions and operations.
These materials may be collected as documentation if, in the inspector's judgment, they are
relevant. All printed matter should be identified with date, inspector's initials, and origin.
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Mechanical Recordings
Electronic records can be entered as evidence if properly dated and signed. Charts, graphs,
and other hard copy documents produced from computer output should be treated as
documentation and handled accordingly.
Copies of Records
Records may be stored in a variety of information retrieval systems, including written or printed
materials, computer or electronic systems, or visual systems such as microfilm and microfiche.
Obtaining Copies of Necessary Records
When copies of records are necessary for an inspection report, storage and retrieval methods
must be considered.
• Written or printed records generally can be photocopied on-site. Portable photocopy
machines may be available to inspectors through the Regional Office. When
necessary, inspectors are authorized to pay a facility a "reasonable" price for the use of
facility copying equipment. If the facility does not have a photocopier and a portable
photocopier is not available, a photocopy machine is usually accessible at a nearby site
(e.g., post office, convenience store). However, inspectors must obtain permission
from the permittee prior to taking records offsite for copying.
- At a minimum, all copies made for or by the inspector should be initialed and dated
for identification purposes. (See identification details below.)
- When photocopying is impossible or impractical, closeup photographs or videotape
may be taken to provide suitable copies.
• Computer or electronic records may require the generation of hard copies for
inspection purposes. Arrangements should be made during the opening conference, if
possible, for these copies.
- Photographs of computer screens possibly may provide adequate copies of records
if other means are not exist.
• Visual systems (microfilm, microfiche) may have photocopying capacity built into the
viewing machine, which can be used to generate copies. Photographs of the viewing
screen may provide adequate copies if hard copies cannot be generated.
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Identification Procedures
Immediate and adequate identification of records reviewed is essential to ensure the
identification of records throughout the EPA custody process and their admissibility in court.
When inspectors are called to testify, they must be able to identify positively each particular
document and state its source and the reason for its collection.
Initial, date, number, and enter the facility's name on each record, and log these items into the
field notebook.
Initialing/Dating. Each inspector should develop a unique system for initialing (or coding) and
dating records and copies of records so that he or she can easily verify their validity. This can
be done by initialing each document in a similar position, or by another method, at the time of
collection. All record identification notations should be made on the back of the document.
The inspector must be able to identify positively that he or she so marked the document.
Numbering. Each document or set of documents substantiating a suspected violation(s)
should be assigned an identifying number unique to that document. The number should be
recorded on each document and in the field notebook.
Logging. Documents obtained during the inspection should be entered in the field notebook
by a logging or coding system. The system should include the identifying number, date, and
other relevant information:
• The reason for copying the material (i.e., the nature of the suspected violation or
discrepancy)
• The source of the record (i.e., type of file, individual who supplied record)
• The manner of collection (i.e., photocopy, other arrangements).
General Considerations
• Originals must be returned to the proper person or to their correct location
• Related records should be grouped together
• Confidential business records should be handled according to the special confidential
provisions discussed below.
Routine Records
The inspector may find it convenient to make copies of some records, such as laboratory
analysis sheets and data summaries, to refresh his or her memory when preparing the
inspection report. It is not always necessary to follow the formal identification and logging
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requirements when such records are obtained for general information purposes or to aid in the
preparation of routine inspection reports.
Confidential Information
Disclosure of Official Information
Inspectors may give general information about EPA programs and activities and describe what
they are doing, but they should be cautious about divulging specific information regarding an
inspection. It is permissible to discuss with the permittee's representative deficiencies
encountered during an evaluation of self-monitoring procedures and the action required to
correct these deficiencies. However, it is generally not advisable to discuss information
collected during the course of an inspection that may indicate the occurrence of a criminal or
civil violation. Therefore, when an inspector has reason to believe that an enforcement action
may be required, no information should be disclosed before consulting with the attorney in the
Regional Office. Caution should be exercised in disclosing findings, and the inspector should
not speculate on the type of action EPA may choose to take.
Trade Secrets and Confidential Business Information
Trade secrets and confidential business information are protected from public disclosure by
Section 308(b)(2) of the CWA. The type of information that may be considered confidential
business information is defined in Title 40, Code of Federal Regulations, Part 2 (40 CFR Part
2).
Section 308(a)(4) of the CWA states that an inspector may sample an effluent, request
information, have access to the location of the effluent, and inspect any monitoring equipment.
The information that is collected is available to the public. If a permittee does not want
inspection information to be available to the public, he or she must request that the EPA
Administrator consider the information confidential. Confidential information includes trade
secrets, such as chemical identity, processes, or formulae. The permittee must show that the
information, if made available, would divulge trade secrets. The information then may be
classified confidential, but still may be disclosed to authorized representatives of EPA
concerned with enforcing the Act.
Therefore, a business is entitled to a claim of confidentiality for al[ information that an inspector
requests or has access to; however, a business may not refuse to release information
requested by the inspector under the authority of Section 308 of the Act on the grounds that
the information is considered confidential or a trade secret. The claim of confidentiality relates
only to the public availability of such data and cannot be used to deny access to a facility to
EPA inspectors performing duties under Section 308 of the Act. A claim of confidentiality may
be made at the time of the inspection or at any time subsequent to the inspection. Claims
must be made in writing and signed by a responsible company official. Information claimed as
confidential can be later reviewed to determine whether the claim is valid.
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Handling Confidential Business Information
Routine security measures will help ensure that reasonable precautions are taken to prevent
unauthorized persons from viewing confidential information. When practical circumstances
prohibit the inspector from following the procedures exactly, he or she should take steps to
protect the information. All confidential information received must be marked as such and
placed in a locked filing cabinet or a safe immediately after the inspection is completed. A
chain-of-custody record must be maintained for all confidential information. Since confidential
information requires special handling procedures, it may be useful to keep it in a separate
notebook. By doing this, only the confidential material, and not the entire notebook of
inspection findings, would have to be kept in a locked filing cabinet.
While Traveling. The inspector may be on the road for several days while conducting
inspections. The inspector is responsible for ensuring that the information collected is
handled securely.
• Documents and field notes are considered secure if they are in the physical possession
of the inspector and are not visible to others while in use.
• Inspection documents contain sensitive information and should be kept in a locked
briefcase. If it is impractical to carry the briefcase, the briefcase may be stored in a
locked area, such as the trunk of a motor vehicle.
• Physical samples should be placed in locked containers and stored in a locked portion
of a motor vehicle. The chain-of-custody procedures provide further protection for
ensuring the integrity of the sample.
In the Office. Only personnel authorized by the Regional Administrator, Division Director,
or Branch Chief will be allowed access to the file. An access log should be maintained
for all transactions. Copies should not be made of information marked "trade secret" and/
or "confidential" unless written authorization has been obtained from the Regional
Administrator, Division Director, or Branch Chief. Requests for access to confidential
information by any member of the public, or by an employee of a Federal, State, or local
agency, must be handled according to the procedures contained in the Freedom of
Information Act regulations (40 CFR Part 2). All such requests should be referred to the
responsible Regional organizational unit.
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NOTES
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2. INSPECTION PROCEDURES
E. Closing Conference
To achieve the most effective results from compliance inspections, the inspector must
communicate results promptly to the facility management and/or operating personnel.
However, the inspector's discussion should be limited to specific findings of the visit and the
inspector should make it clear that all the findings may not be presented during the
conference. If appropriate, findings should be compared with the permittee's NPDES permit
requirements, consent decrees, administrative orders, and other enforcement actions.
Precautions and Guidelines
Although a discussion of the inspection results is important, certain precautions are essential:
• The inspector should generally not discuss compliance status or any legal effects or
enforcement consequences with the permittee's representative or with facility operating
personnel.
• The inspector should refrain from recommending a particular consultant or consulting
firm, even if asked to do so. Inspectors should tell the permittee's representative to
contact a professional society or approved listing for advice concerning this matter.
These guidelines are subject to rules promulgated by the Regional Administrator or State
Director regarding permittee contacts in the Region/State.
Deficiency Notice
The inspector may issue a Deficiency Notice that specifies existing or potential problems in a
permittee's self-monitoring program. Issuing a Deficiency Notice on-site or after the site visit
provides a swift and simple method for improving the quality of data from NPDES self-
monitoring activities. An example Deficiency Notice and EPA's memorandum on Deficiency
Notice Guidance are provided in Appendix D. Notices allow the inspector formally to assign
responsibility to the permittee and to track each step of the compliance/enforcement process.
The Deficiency Notice also helps the permittee to comply with the self-monitoring requirements
of the permit.
This tool should be used in conjunction with any type of NPDES compliance inspection during
which the inspector identifies problems with the permittee's self-monitoring activities. It is to
be used by the inspector only to alert permittees to deficiencies in their self-monitoring
activities. The enforcement office of the regulatory authority, not the inspector, handles
effluent violations. (Under the proposed amendments to the CWA, inspectors may be able to
issue field citations.)
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Inspectors can issue the Deficiency Notice to a permittee immediately following a compliance
inspection, or after the site visit is completed, if they discover any permit deficiencies in the
following seven categories that the Notice addresses:
Monitoring location
Flow measurement
Sample collection/holding time
Sample preservation
Test procedures, Section 304(h), 40 CFR Part 136
Recordkeeping
Other self-monitoring deficiencies.
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2. INSPECTION PROCEDURES
F. Inspection Report
The adequacy of compliance follow-up to correct problems or deficiencies noted during
inspection greatly depends on the report prepared by the inspector. The sections of this
chapter detail procedures for collecting and substantiating the information used to prepare this
report. Once collected, however, the material must be organized and arranged so that
compliance personnel can make maximum use of it. The information presented in this section
provides general guidelines for organizing evidence and preparing an inspection report.
Objective of the NPDES Inspection Report
The objective of an NPDES inspection report is to organize and coordinate all inspection
information and evidence into a comprehensive, usable document. To meet this objective,
information in an inspection report must be presented in a clear, well-organized manner. The
information should be objective and factual; the report must not speculate on the ultimate
result of the inspection findings. Of particular importance are the following:
• Only accurate information may be included in the report. It should be factual and
based on sound inspection practices. Observations should be the verifiable result of
firsthand knowledge. Compliance personnel must be able to depend on the accuracy
of all information.
• Information in an inspection report should be relevant to the subject of the report.
Irrelevant facts and data will clutter a report and may reduce its clarity and usefulness.
Personal comments and opinions should be avoided.
• Suspected violation(s) should be substantiated by as much factual, relevant information
as is feasible to gather. All information pertinent to the subject should be organized
into a complete package. Documentary support (e.g., photographs, statements,
sample documentation) accompanying the report should be referenced clearly so that
anyone reading the report will get a complete, clear overview of the situation. The
more comprehensive the evidence is, the better and easier the prosecution's task will
be.
Elements of a Report
Although specific information requirements for an inspection report will vary, most reports will
contain the same basic elements:
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• NPDES Compliance Inspection Report Form
• Supplementary narrative information
• Copies of completed checklists
• Documentary support.
NPDES Compliance Inspection Report Form
The inspector is responsible for reporting all compliance inspection activities by completing the
current Compliance Inspection Report Form 3560-3 as soon as possible after the inspection.
A copy of the form is included as Appendix E. The Federal or State compliance office should
forward the inspection report form to the regulatory authority no later than 30 days after
completion of the inspection. Copies should be sent to the permittee in a timely manner
(generally within 30 days of inspection date) except when formal enforcement procedures are
under way. In this instance, the case attorney will direct any disclosure of data.
Supplementary Narrative Information
Supplementary narrative information could be a memorandum in the case of routine
inspections or a narrative report when major violations are detected. When a narrative report
is necessary to describe fully a compliance inspection, the contents of the report should focus
on supporting or explaining the information provided in the Compliance Inspection Report
Form.
The narrative report should be a concise, factual summary of observations and activities,
organized logically and legibly, and supported by specific references to accompanying
documentary support.
A work plan will simplify preparation and will help ensure that information is organized in a
usable form. Basic steps in writing the narrative report include the following:
Reviewing the Information. The first step in preparing the narrative is to collect all information
gathered during the inspection. The inspector's field notebook should be reviewed in detail.
All evidence should be reviewed for relevance and completeness. A telephone call or, in
unusual circumstances, a follow-up visit may be needed to obtain additional or supplementary
information.
Organizing the Material. The information may be organized according to need, but it should
be presented logically and comprehensively. The narrative should be organized so that it is
understood easily.
Referencing Accompanying Material. All documentary support accompanying a narrative
report should be referenced clearly so that the reader will be able to locate the items easily.
The "Documentation" section in this chapter provides details on document identification. The
inspector should check all documentary support for clarity before writing the report.
Writing the Narrative Report. Once the material collected by the inspector has been reviewed,
organized, and referenced, the narrative can be written. The purpose of the narrative is to
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record factually the procedures used in, and findings resulting from, the evidence-gathering
process. The inspector should refer to routine procedures and practices used during the
inspection, but should detail facts relating to potential violations and discrepancies. The field
notebook is a guide for preparing the narrative report.
If the inspector has followed the steps presented in this manual, the report will develop
logically from the organizational framework of the inspection. In preparing the narrative, the
inspector should make simplicity paramount.
• Write simply; avoid stilted language.
• Use the active, not passive, voice: (e.g., "He said that. . ." rather than "It was said that
. . .").
• Keep paragraphs brief and to the point.
• Avoid repetition.
• Proofread the narrative carefully.
Copies of Completed Checklists
Comprehensive checklists are included in the technical chapters of this manual. When
appropriate, these checklists may be used by the inspector to collect information during the
inspection or they may be modified by the Region or State to address additional specific
concerns. Copies of all completed checklists should be included in the inspection report.
Documentary Support
All documentation produced or collected by the inspector to provide evidence of suspected
violations should be included in the inspection report. The "Documentation" section in this
chapter provides details on obtaining and organizing this material.
The Permit Compliance System (PCS)
The inspection office should ensure that all data listed in Section A of the NPDES Compliance
Inspection Report Form 3560-3 are entered into the PCS, which is used for national tracking of
NPDES permit information. An inspection is not credited to the inspection program office until
it has been coded into the PCS. Therefore, timely completion of reports and data entry into
PCS is essential to follow up effectively a compliance inspection. Every effort should be made
to ensure that data are entered no later than 30 days after the inspection is completed.
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*** NOTES ***
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3. DOCUMENTATION/
RECORDKEEPING AND
REPORTING
Contents Page
A. Inspection Authority and Objectives
Authority and Objectives 3-1
B. Evaluation Procedures
Verification, Recordkeeping, and Reporting Evaluation Procedures 3-3
Compliance Schedule Status Review 3-5
POTW Pretreatment Requirements Review 3-7
Indepth Investigations 3-8
C. Verification, Recordkeeping, and Reporting Evaluation Checklist
Verification, Recordkeeping, and Reporting Evaluation Checklist 3-11
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Chapter Three Contents
*** NOTES ***
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3. DOCUMENTATION/
RECORDKEEPING AND
REPORTING
A. Inspection Authority and
Objectives
Authority and Objectives
Statutory Recordkeeping Authority:
Regulatory Requirements:
Inspection Authority:
Clean Water Act (CWA) §308 and §402
40 Code of Federal Regulations (CFR)
Parts 122, 401, 403, 405-471, and 503, as
applicable
CWA §308
The National Pollutant Discharge Elimination System (NPDES) permit system requires
permittees to maintain records and report periodically on the amount and nature of discharged
effluent waste components. The permit stipulates recordkeeping and reporting conditions.
Evaluations are conducted at selected permittee facilities to determine compliance with permit
requirements. The procedures listed below should be used for these routine inspections. If
suspected violations are disclosed during the routine evaluation, a more intensive investigation
should be conducted.
A review of facility records should determine that recordkeeping requirements are being met.
The following questions should be answered in particular:
Is all required information available?
Is the information current?
Is the information being maintained for the required time period?
Do the records reviewed indicate areas needing further investigations?
Are the records organized?
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Chapter Three Documentation/Recordkeeping and Reporting
*** NOTES ***
3-2
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3. DOCUMENTATION/
RECORDKEEPING AND
REPORTING
B. Evaluation Procedures
Verification, Recordkeeping, and Reporting Evaluation Procedures
During the facility site inspection, the inspector should verify the following requirements of the
permit:
• That the number and location of discharges are as described in the permit
• That all discharges are in accordance with the general provisions of the permit, such
as no noxious odors, no discharge, no visible entrained solids in discharge, no
deposits at or downstream of the outfall, no color change in the receiving stream, and
no fish or vegetation kills near the outfalls.
The inspector should review the permit to determine recordkeeping and reporting
requirements. Throughout the inspection, the facility's operations should be compared with
the permit to verify that required permit activities are correct, current, and complete. Some of
the information needed to verify the permit can be obtained during the opening conference
and compared with the facility permit. This information includes:
• Correct name and address of facility
• Correct name and location of receiving waters
• Number and location of discharge points
• Principal products and production rates (where appropriate).
The inspector should check for records that will verify that notification has been made to
Environmental Protection Agency (EPA) or to the State when (1) discharges differ from those
stated in the permit, (2) a permit violation has occurred, and (3) bypassing has occurred. The
inspector should also check to ensure that the appropriate records are maintained for a
minimum of 3 years. These records may include the following:
• Sampling and Analysis Data
- Dates, times, and locations of sampling
- Sample types collected
- Analytical methods and techniques
- Results of analyses
- Dates and times of analyses
- Name(s) of analytical and sampling personnel.
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Chapter Three Documentation/Recordkeeping and Reporting
Monitoring Records
- Discharge Monitoring Reports (DMRs), including information on flow, pH, Dissolved
Oxygen (DO), etc., as required by permit
- Original charts from continuous monitoring instrumentation.
Laboratory Records
- Calibration and maintenance of equipment
- Calculations (i.e., on bench sheets or books)
- Quality Assurance/Quality Control (QA/QC) analysis data.
Facility Operating Records
- Daily operating log
- Summary of all laboratory tests run and other required measurements, including
reference test method used (general reference to Standard Methods or 40 CFR Part
136 methods is not adequate)
- Chemicals used (pounds of chlorine per day, etc.)
- Weather conditions (temperature, precipitation, etc.)
- Equipment maintenance completed and scheduled
- Spare parts inventory
- Flowmeter and pH meter calibration records.
Treatment Plant Records (required as part of the Federal Construction Grants
program)
- Plant Operations and Maintenance (O&M) Manual
- Percent removal records
- "As built" engineering drawings
- Copy of construction specifications
- Equipment supplier manual
- Data cards on all equipment.
Management Records
- Average monthly operating records
- Annual reports
- Emergency conditions (power failures, bypass, and chlorine failure reports, etc.).
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Chapter Three Documentation/Recordkeeping and Reporting
• Pretreatment Records
- Publicly Owned Treatment Works (POTW) and industrial monitoring and reporting
requirements
- Industrial user discharge data
- Compliance status records
- POTW enforcement initiatives.
• Spill Prevention Control and Countermeasure (SPCC) Plan
When required, a properly completed SPCC Plan should be available. The inspector
also may gather information on the SPCC and forward this information to the
appropriate program office for follow-up action.
• Best Management Practices (where required)
Two types of Best Management Practice (BMP) plans are included in NPDES permits:
- BMP plans to minimize or prevent release of significant amounts of any toxic or
hazardous pollutants to public waters. The plans may discuss general operations
and maintenance of the plant, good housekeeping procedures on the facility
grounds, and other plans and procedures specific to best management of the
facility.
- Site-specific BMP plans to address particular toxic or hazardous chemicals or other
conditions particular to the facility. Site-specific BMP may include procedures,
monitoring requirements, construction of barriers such as dikes and berms, or other
appropriate measures for solving specific problems.
In addition, inspectors should ensure that sludge records to verify compliance with 40 CFR
Part 503 are maintained for a minimum of 5 years. Certain records that need to be reviewed
(such as sludge records and laboratory records) may be kept offsite.
The inspector should document all inspection activities (see Chapter Two, Section D).
Inadequacies, discrepancies, or other problems disclosed during this review may warrant more
intensive investigation.
Compliance Schedule Status Review
If the permit contains a compliance schedule or if the facility is under an enforcement action
with a compliance schedule, a status review should be conducted to determine:
• Whether the permittee is conforming to the compliance schedule and, if not, whether
final requirements will be achieved on time
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Chapter Three Documentation/Recordkeeping and Reporting
• The accuracy of reports relating to compliance schedules
• The length of delay associated with a particular construction violation
• Whether any schedule violations are beyond the control of the discharger
• Whether requests for permit modifications are valid.
If the permit contains a compliance schedule for actions such as beginning new construction,
contract and equipment orders, authorization and financing arrangements, and/or attainment
of operational status, the schedule should be addressed in detail only if the need becomes
apparent during records review and preparation of the inspection plan. The specific
compliance schedule actions are described below.
Construction Progress
The inspector must know whether contracts for labor and material have been fulfilled and
whether the permittee or the permittee's engineering consultant is monitoring progress. These
aspects are extremely important, particularly in plants where numerous contracts are likely for
labor and equipment.
If the permittee or the engineering consultant reports that construction or acquisition of
equipment is behind schedule, the inspector should:
• Ask to see the permittee's or the resident engineer's progress report and determine
whether the report indicates that the final compliance schedule required by the permit
can be met.
• If the report indicates that the final date will not be met, advise the permittee that the
compliance schedule of the NPDES permit requires the permittee to notify the permit-
issuing authority promptly of any possible delay in achieving compliance and of
measures taken to minimize the delay.
• Inquire whether the facility superintendent or chief operator and operating personnel
are receiving adequate training concerning the operational aspects of the new
treatment unit while construction is under way. They must be prepared to perform the
essential operating functions when the facility is placed in service.
Construction Contracts and Equipment Orders
The inspector should review the appropriate documents to determine whether the permittee
has obtained the necessary approval to begin construction. The inspector should note the
start and completion dates (or scheduled,delivery dates in service or equipment contracts).
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Chapter Three Documentation/Recordkeeping and Reporting
Authorization and Financing
If construction is incomplete, the inspector should determine whether the permittee has the
authority and financial capability (mortgage commitments, corporate resolution, etc.) to
complete the required structures.
Attainment of Operational Status
If construction has been completed but the facility is not yet operational, the inspector should
determine whether appropriate procedures are being used to ensure attainment of working
status at the earliest possible time. The inspector should verify the following:
• Adequate self-monitoring procedures have been initiated. It is especially important that
the result of operational and effluent quality monitoring be reviewed to determine
whether progress is being made toward optimum efficiency in each treatment unit and
in the entire plant.
• Adequate recordkeeping procedures have been established or initiated.
• Adequate work schedules and assignments have been established. (For municipal
facilities, the O&M Manual should provide essential guidance.)
POTW Pretreatment Requirements Review
The inspector must collect specific information to evaluate compliance with pretreatment
requirements. The procedures developed to collect this information are summarized below
and discussed in greater detail in Chapter Nine, "Pretreatment."
As part of the inspection, the inspector must collect information about the POTW's compliance
with its approved pretreatment program and applicable regulations as well as the compliance
status of its industrial users with categorical pretreatment standards or locally developed
discharge limitations. The inspector should review POTW records to determine the following:
• Number of contributing industries, including the number of significant industrial users.
• Whether all industries are properly identified and classified.
• Whether industries have submitted required reports and notifications to the POTW.
These include baseline monitoring reports, 90-day compliance reports, periodic
compliance reports, notifications of changed discharge, potential problem discharges,
violation and resampling, and hazardous waste discharge.
• Number of contributing industries in compliance with applicable standards.
• Whether permits containing all required elements have been issued to significant
industrial users in a timely manner.
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Chapter Three Documentation/Recordkeeping and Reporting
Whether inspections and sampling (including evaluation of the need for slug control
plans) of significant industrial users are conducted at the required frequency.
Whether the POTW has notified all affected users of classification and applicable
standards and requirements, including Resource Conservation and Recovery Act
(RCRA) obligations.
Whether appropriate enforcement actions have been taken against all noncompliant
industries and whether the names of all users in significant noncompliance are
published at least annually.
Whether contributing industries with compliance schedules are meeting applicable
schedule deadlines and compliance schedule reporting requirements.
Indepth Investigations
An indepth inspection of a permittee's records and reports will be conducted when necessary
to substantiate a suspected violation, to verify self-monitoring data that may be used as
corroborative evidence in an enforcement action, or to confirm apparent sampling, analysis, or
reporting discrepancies discovered during the limited inspection. Discrepancies warrant an
indepth review if, for example:
• The discharge does not meet required standards and nd definite operational problems
have been established
• Self-reported data are suspected of being grossly inaccurate and the problem appears
to be with recordkeeping procedures and/or the filing of reports
• The cursory review indicates omissions or laxity in the preparation of records
• There is evidence of falsification of records.
If more guidance or assistance is needed in performing an indepth investigation, the inspector
should confer with his or her supervisor.
Indepth Investigation Procedures
The following procedures should guide the inspector in conducting an indepth investigation:
• Determine Investigation Objective. What is the specific purpose of the investigation?
• Determine Information Needed. What specific data will substantiate a violation or
respond to the investigation objective?
• Determine Data Source. What records will contain these required data?
• Review Inspection Authority. Authority to inspect under Section 308 is limited to those
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Chapter Three Documentation/Recordkeeping and Reporting
records required by the permit. Specific authority may be necessary to inspect other
documents.
Inspect Direct and Indirect Data Sources. Examine records likely to provide the
required data directly. In the absence of direct data, indirect sources of information
can be used to develop a network of information relevant to the data being sought.
Take Statements From Qualified Facility Personnel. See Chapter Two, Section D, for
procedures.
Prepare Documentation. Copy and identify all records relevant to the information being
sought; see Chapter Two, Section D, for specific procedures.
Follow Confidentiality Procedures. Any record inspected may be claimed by the facility
as confidential. Such records must be treated in accordance with EPA procedures;
see Chapter Two, Section D, the discussion on Confidential Business Information.
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Chapter Three Documentation/Recordkeeping and Reporting
***NOTES***
3-10
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3- DOCUMENTATION/
RECORDKEEPING AND
REPORTING
C. Verification, Recordkeeping, and
Reporting Evaluation Checklist
VERIFICATION. RECORDKEEPING. AND REPORTING EVALUATION CHECKLIST
A. PERMIT VERIFICATION
Mailing Address:
Brief Facility Description:
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1. Inspection observations verify information contained in permit.
2. Current copy of permit is onsite.
3. Name and mailing address of permittee are correct.
4. Facility is as described in permit.
5. Notification was given to EPA/State of new, different, or increased
discharges.
6. Accurate records of influent volume maintained, when appropriate.
7. Number and location of discharge points are as described in permit.
8. Name and location of receiving waters are correct.
9. All discharges are permitted.
10. Federal Construction Grant funds were used to build plant.
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Chapter Three
Documentation/Recordkeeping and Reporting
VERIFICATION. RECORDKEEPING, AND REPORTING EVALUATION CHECKLIST
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
B.
RECORDKEEPING AND REPORTING EVALUATION
1 . Records and reports are maintained as required by permit.
2. All required information is available, complete, and current.
3. Information is maintained for 3 years.
4. If the facility monitors more frequently than required by permit
(using approved methods), these are results reported.
5. Analytical results are consistent with data reported on DMRs.
6. Sampling and analyses data are adequate and include:
a. Dates, times, and location of sampling
b. Name of individual performing sampling
c. Analytical methods and techniques
d. Results of analyses and calibration
e. Dates of analyses
f. Name of person performing analyses
g. Instantaneous flow at grab sample stations.
7. Monitoring records are adequate and include:
a. Flow, pH, DO, etc., as required by permit
b. Monitoring charts kept for 3 years
c. Flowmeter calibration records kept.
8. Laboratory equipment calibration and maintenance records are adequate.
9. Plant records* are adequate and include:
a. O&M Manual
b. "As-built" engineering drawings
c. Schedules and dates of equipment maintenance repairs
d. Equipment supplies manual
e. Equipment data cards.
* Required only for facilities built with Federal construction grant funds.
10. Pretreatment records are adequate and contain inventory of industrial
waste contributors, including:
a. Monitoring data
b. Inspection reports
c. Compliance status records
d. Enforcement actions.
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Chapter Three
Documentation/Recordkeeping and Reporting
VERIFICATION. RECORDKEEPING. AND REPORTING EVALUATION CHECKLIST
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
C. COMPLIANCE SCHEDULE STATUS REVIEW
1. Permittee is meeting compliance schedule.
2. Permittee has obtained necessary approvals to begin construction.
3. Financing arrangements are complete.
4. Contracts for engineering services have been executed.
5. Design plans and specifications are completed.
6. Construction has begun.
7. Construction is on schedule.
8. Equipment acquisition is on schedule.
9. Construction has been completed.
10. Startup has begun.
11. Permittee has requested an extension of time.
12. Permittee has met compliance schedule.
D. POTW PRETREATMENT REQUIREMENTS REVIEW
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
THE FACILITY IS SUBJECT TO PRETREATMENT REQUIREMENTS
1. Status of POTW pretreatment program
a. The POTW pretreatment program has been approved by EPA. (If
not, is approval in progress?)
b. The POTW is in compliance with the pretreatment program
compliance schedule. (If not, note why, what is due, and intent of
the POTW to remedy.)
2. Status of Compliance with Categorical Pretreatment Standards.
a. How many industrial users of the POTW are subject to Federal or
State pretreatment standards?
b. Are these industries aware of their responsibility to comply with
applicable standards?
c. Have baseline monitoring reports (403.12) been submitted for these
industries?
i. Have categorical industries in noncompliance (on BMR reports)
submitted compliance schedules?
ii. How many categorical industries on compliance schedules are
meeting the schedule deadlines?
d. If the compliance deadline has passed, have all industries submitted
90-day compliance reports?
e. Are all categorical industries submitting the required semiannual
report?
f. Are all new industrial discharges in compliance with new source
pretreatment standards?
g. Has the POTW submitted an annual pretreatment report?
h. Has the POTW taken enforcement action against noncomplying
industrial users?
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Chapter Three
Documentation/Recordkeeping and Reporting
VERIFICATION. RECORDKEEPING. AND REPORTING EVALUATION CHECKLIST
(Continued)
Yes No N/A
Yes No N/A
Is the POTW conducting inspections of industrial
contributors?
3. Are the industrial users subject to Prohibited Limits (403.5) and
Local Limits more stringent than EPA in compliance? (If not,
explain why, including need for revision of limits.)
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4. FACILITY SITE REVIEW
Contents Page
A. Objectives
B. Physical Inspection of the Facility
General Conditions in Overall Plant 4-4
Preliminary Treatment 4-5
Primary Clarifier 4-6
Secondary Biological Treatment Units 4-6
Secondary Clarifier 4-7
Advanced Physical Treatment Units 4-8
Chlorination and Dechlorination Units 4-9
Sludge Handling 4-9
Polishing Ponds or Tanks 4-12
Plant Effluent 4-12
Flow Measurement 4-12
Chemical Treatment Units 4-13
General Housekeeping 4-13
Production Changes 4-13
C. Operation and Maintenance Evaluation
Operation Evaluation 4-15
Maintenance Evaluation 4-16
D. References and Facility Site Review Checklist
References 4-27
Facility Site Review Checklist 4-28
List of Tables
4-1 Operation and Maintenance Function Evaluation Questions 4-19
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Chapter Four Contents
***NOTES***
4-ii
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4. FACILITY SITE REVIEW
A. Objectives
In performing a facility site review, an inspector examines process treatment units, sampling
and flow monitoring equipment, outfalls, and the receiving stream. In particular, the inspector
focuses on areas of the permittee's premises where pollutants are generated, pumped,
conveyed, treated, stored, or disposed of. The proper conduct of a facility site review requires
that the inspector understand fully the wastewater treatment processes used at the facility and
how each process fits into the overall treatment scheme.
The objectives of a facility site review are to:
• Assess the conditions of the facility's current treatment processes and operations
• Evaluate the permittee's operation and maintenance activities
• Check the completeness and accuracy of the permittee's performance/compliance
records
• Determine whether the treatment units are achieving the required treatment
efficiencies.
During the overall review of the facility, the compliance inspector becomes more
knowledgeable about the facility being inspected, reviews areas that may indicate problems
with effluent limitations, and evaluates overall performance of the treatment facility. The
information presented in this chapter is comprehensive and is based on performing an
inspection at a Publicly Owned Treatment Works (POTW). Inspectors should use only the
information applicable to a particular situation. A Facility Site Review Checklist for the
inspectors' use is included at the end of this chapter.
4-1
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Chapter Four Facility Site Review
*** NOTES ***
4-2
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Chapter Four Facility Site Review
4. FACILITY SITE REVIEW
B. Physical Inspection of the Facility
During the "walk-through" of the facility, the inspector should consider the operational factors
listed below. The physical inspection should be carefully documented. Areas that should be
covered are the following:
• Influent characteristics, including:
- Appearance (color, odor, etc.)
- Combined sewer loads
- Infiltration/inflow
- Industrial contributions
- Diurnal/seasonal loading variations
Process control
Unit operations including supply of treatment chemicals
Equipment condition
Maintenance and operation staff
Safety controls and equipment
Effluent characteristics, including:
- Appearance of outfall
- Receiving stream appearance including any staining or deposits
- Evidence of toxicity of the discharge
• Other conditions particular to the plant.
Environmental Protection Agency's (EPA's) Field Manual for Performance Evaluation and
Trouble Shooting at Municipal Wastewater Facilities (USEPA 1978), published by the
Municipal Operations Branch of EPA, is a good reference for operational characteristics of
plants.
The physical inspection may lead the inspector to determine:
• Whether a major facility design problem may require an engineering solution
• Whether problems can be solved through proper operation and maintenance of the
treatment facilities
• Whether periodic equipment malfunctions need to be addressed by complete overhaul
or replacement of equipment.
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Chapter Four Facility Site Review
If a facility design problem exists, one of the recommendations will be to develop engineering
solutions. In this case, the inspector must evaluate the operation and maintenance
procedures from the viewpoint of what can be done to simplify the solution. When the
inspection findings indicate that specific practices of the facility contribute to or cause
problems, the inspector should detail the problems. When possible, the inspector should use
the information to evaluate the operation and maintenance procedures.
When conducting the walk-through, the inspector should be aware of and look for physical
conditions that indicate past, existing, or potential problems. The presence of these conditions
will give the inspector an idea of the types of problems present, the parts of the treatment
process causing the problems, and the potential solution to existing problems. Conditions to
look for in the plant generally and in specific processes are listed in the following sections.
General Conditions in Overall Plant
General Indicators
• Excessive scum buildup; grease, foam, or floating sludge in clarifiers.
• Hydraulic overload caused by storms or discharges of cooling water.
• Noxious odors in wet wells and grit chambers and around aerobic and anaerobic
biological units, scum removal devices, and sludge handling facilities.
• Evidence of severe corrosion at the treatment plant and in the collection system.
• Discoloration of the ground or a strong chemical smell may indicate past spills at the
plant; further investigation of spills may be warranted.
• Vital treatment units out of service for repairs. Determine when the units went out of
service, the type of failure, and when they will be put back in service.
• Excessive noise from process or treatment.
• Any unusual equipment intended to correct operation problems (e.g., special pumps,
floating aerators in diffused air systems, chemical feeders, temporary construction or
structures, or any improvised system).
• Ruptures in chemical feed lines.
Flow Indicators
• Surcharging of influent lines, overflow weirs, and other structures.
• Flowthrough bypass channels.
• Overflows at alternative discharge points, channels, or other areas.
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Chapter Four Facility Site Review
• Excessive septage dumping by septic tank pumpers.
• Flow from unknown source or origin
• Open-ended pipes that appear to originate in a process or storage area and
periodically contain flows to the ground or to surface water. Although these pipes have
been disconnected from a closed system or otherwise removed from service, they can
still be connected to a discharge source.
Unusual Wastes Indicators
• Collected screenings, slurries, sludges, waste piles, or by-products of treatment. Their
disposal, including runoff of any water, must be such that none enters navigable waters
or their tributaries.
• Improper or lack of recycling of filtrates and supernatants from sludge beds.
• Improper storage of chemicals and hazardous substances with particular attention to
the proper diking of chemicals and hazardous substances and segregation of
incompatible chemicals. Generally, spill containment should be such that the dike
could contain the contents of the largest tank.
• Spills or mishandling of chemicals.
Preliminary Treatment
Screening
• Excessive screen clogging
• Oil and grease buildup
• Disposal of screenings.
Shredding/Grinding
• Excessive buildup of debris against screen
• Grit chamber clogged or subject to odors.
Grit Removal
• Excessive organic content of grit
• Wear of grit removal/handling equipment
• Excessive odors in grit removal area.
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Chapter Four Facility Site Review
Flow Equalization
• Excessive odors
• Inoperable aerators, if aerated
• Ability to bypass directly to surface water.
Primary Clarifier
General Indicators
Excessive gas bubbles or grease on surface
Black and odorous wastewater
Poor suspended solids removal in primary clarifier
Excessive buildup of solids in center well of circular clarifier
Unlevel discharge weirs
Fouling of overflow weirs
Evidence of short circuiting
Ineffective scum rake
Scum overflow or lack of adequate scum disposal, full scum pit
Excessive floating sludge
Excessive sludge on bottom, inadequate sludge removal
Noisy sludge scraper drive
Broken sludge scraper.
Secondary Biological Treatment Units
Trickling Filter
Trickling filter ponding (indicating clogged media)
Leak at center column of trickling filter's distribution arms
Uneven distribution of flow on trickling filter surface
Uneven or discolored growth
Excessive sloughing of growth
Odor
Clogging of trickling filter's distribution arm orifices
Restricted rotation of distribution arms
Filter flies, worms, or snails
Ice buildup on trickling filter media or distribution arms.
Rotating Biological Contactors
• Development of white biomass on rotating biological contactor (RBC) media
• Excessive sloughing of growth
• Excessive breakage of rotating disks or shafts in RBC units
• Excessive breakage of paddles on brush aerators
• Shaft, bearing, drive gear, or motor failure on disk or brush aerators.
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Chapter Four Facility Site Review
Activated Sludge Tanks
• Dead spots in aeration tanks; dark foam or bad odor in aeration tanks
• Failure of surface aerators
• Inoperative air compressors
• Air rising unevenly
• Excessive air leaks in compressed air piping
• Dark mixed liquor in aeration tank
• Dark foam or bad odor on aeration tanks
• Stable dark tan foam on aeration tanks that sprays cannot break up
• Thick billows of white, sudsy foam on aeration tank
• Low Dissolved Oxygen (DO, < 1.0 mg/l) in aeration tank.
Stabilization Ponds/Lagoons
• Erosion of stabilization pond bank or dike
• Excessive foliage or animal burrows in pond bank or dike
• Excessive weeds in stabilization ponds
• Foaming and spray in aerated lagoon
• Dead fish or aquatic organisms
• Buildup of solids around influent pipe
• Excessive scum on surface.
Secondary Clarifier
General Indicators
• Excessive gas bubbles on surface
• Fouling of overflow weirs
• Unlevel overflow weirs
• Evidence of short circuiting
• Excessive buildup of solids in center well of circular clarifier
• Deflocculation in clarifier
• Pin floe in overflow
• Ineffective scum rake
• Floating sludge on surface
• Billowing sludge
• Excessively high sludge blanket
• Clogged sludge withdrawal ports on secondary clarifier.
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Chapter Four Facility Site Review
Advanced Physical Treatment Units
Filtration
• Filter surface clogging
• Short filter run
• Gravel displacement of filter media
• Formation of mud balls in filter media
• Air binding of filter media v
• Loss of filter media during backwashing
• Recycled filter backwash water in excess of 5 percent.
Microscreening
• Erratic rotation of microscreen drums.
Activated Carbon Adsorption
• Excessive biological growth resulting in strong odor
• pH above 9.0 S.U.
• Plugged carbon pores
• Presence of carbon fines (dust) in effluent.
Nitrification
4
• Hydraulic overload.
Denitrification
• Temperature below 15°C
• pH below 6.0 S.U. or above 8.0 S.U.
• Excessive methanol.
Ammonia Stripping
• Excessive hydraulic loading rate
• Tower packing coated with calcium carbonate
• pH below 10.8 S.U.
• Inadequate tower packing depth
• Air temperature below 65°F.
4-8
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Chapter Four Facility Site Review
Chlorination and Dechlorination Units
Chlorination
• Sludge buildup in contact chamber
• Gas bubbles
• Inadequate retention time
• Floating scum and/or solids
• Evidence of short circuiting
• Inadequate ventilation of chlorine feeding room and storage area
• High temperatures in Chlorination rooms
• Improper operation of automatic feed or feedback control
• Excessive foaming downstream
• Evidence of toxicity downstream (dead fish, other dead organisms)
• Improper chlorine feed, storage, and reserve supply.
Dechlorination
• Improper storage of sulfur dioxide cylinders
• Inadequate ventilation of sulfur dioxide feeding room
• Automatic sulfur dioxide feed or feedback control not operating properly
• Depressed DO after dechlorination
• Proper storage and mixture of sodium metabisulfite containers
• Reduced efficiency of activated carbon dechlorination units because of organic and
inorganic compound interference.
Sludge Handling
General Indicators
• Inadequate sludge removal from clarifiers or thickeners
• Poor dewatering characteristics of thermal treated sludge
• Thickened sludge too thin
• Fouling of overflow weirs on gravity thickeners
• Air flotation skimmer blade binding on beaching plate
• Substantial down time of sludge treatment units
• Sludge disposal inadequate to keep treatment system in balance
• Sludge decant or return flows high in solids.
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Chapter Four Facility Site Review
Sludge Anaerobic Digestion
• Inoperative mechanical or gas mixers
• Inoperative sludge heater
• Floating cover of anaerobic digester tilting
• Inadequate gas production
• Gas burner not burning or inoperative
• Supernatant exuding a sour odor from either primary or secondary anaerobic digester
• Excessive suspended solids in supernatant
• Supernatant recycle overloading the Wastewater Treatment Plant (WWTP)
• pH problems from industrial wastewaters with high sugar content.
Sludge Aerobic Digestion
Excessive foaming in tank
Objectionable odor in aerobically digested sludge
Insufficient dissolved oxygen in digester
Digester overloaded
Clogging of diffusers in digester
Mechanical aerator failure in digester
Inadequate supernatant removal from sludge lagoons.
Sludge Drying/Filtering
Drying beds
Poor sludge distribution on drying beds
Vegetation in drying beds (unless reed design)
Dry sludge remaining in drying beds
Inadequate drying time on drying beds
Some unused drying beds
Dry sludge stacked around drying beds where runoff may enter navigable waters
Filtrate from sludge drying beds returned to front of plant.
Centrifuge
• Excessive solids in fluid phase of sample after centrifugation
• Inadequate dryness of centrifugal sludge cake.
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Chapter Four Facility Site Review
Filter Press
• High level of solids in filtrate from filter presses or vacuum filters
• Thin filter cake caused by poor dewatering
• Vacuum filter cloth binding
• Low vacuum on filter
• Improperly cleaned vacuum filter media
• Sludge buildup on belts and/or rollers of filter press
• Excessive moisture in belt filter press sludge cake
• Difficult cake discharge from filter presses
• Filter cake sticks to solids-conveying equipment of filter press
• Frequent media binding of filter press
• Sludge blowing out of filter press
• Insufficient run time of sludge dewatering equipment.
Lagoon
• Objectionable odor from sludge lagoon
• Broken dikes between sludge drying lagoons
• Unlined sludge lagoons
• Sludge lagoons full, overflowing sludge back to plant or to natural drainage.
Composting
• Piles that give off foul odor
• Inoperable blower
• Temperature does not reach 122-140°F (50-60°C).
Sludge Disposal
• Sludge constituents not analyzed before disposal
• Sludge not transported in appropriate and approved vehicle
• Surface runoff of sludge at land application site
• Liquid sludge (i.e., less than 10 percent solids) applied to landfill site
• Inadequate coverage of sludge in subsurface plow injection system
• Malodors generated at land application site
• Slow drying of soil-sludge mixture in subsurface injection system
• Sludge ponding at land application sites
• Flies breeding and/or odors at landfill site
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Chapter Four Facility Site Review
• Inadequate burial of sludge at landfill site
• Excessive erosion at sludge sites
• Waste sludges disposed of onsite in nonpermitted sites or in landfills, surface
impoundments, or land application units not according to Federal, State, or local
regulations
• Inadequate runoff control at landfill or land application sites.
Polishing Ponds or Tanks
• Objectionable odor, excessive foam, floating solids, or oil sheens in polishing ponds or
tanks
• Solids or scum accumulations in tank or at side of pond
• Evidence of bypassed polishing ponds or tanks because of low capacity.
Plant Effluent
• Excessive suspended solids, turbidity, foam, grease, scum, color, and other
macroscopic particulate matter present
• Potential toxicity (dead fish, dead plants at discharge)
• Stained sediments in receiving waters.
Flow Measurement
• Improper placement of flow measurement device
• Flow totalizer not calibrated
• Buildup of solids in flume or weir
• Broken or cracked flume or weir
• Improperly functioning magnetic flowmeter
• Clogged or broken stilling wells
• Weir plate edge corroded or damaged, not sharp edged (< 1/8"), or not level
4-12
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Chapter Four Facility Site Review
• System not capable of measuring maximum flow
• Sizing of system adequate to handle flow range
• Flow measurement error greater than ± 10%
• Flow measurement that includes all wastewater discharged and does not include
wastestreams that are recirculated back to the treatment plant.
Chemical Treatment Units
• Evident heavy corrosion
• No portion-measuring device at feed unit
• pH measuring not evident at pH adjustment tank
• Chemicals left in open atmosphere
• Chemicals outdated
Chemical containers stored improperly or hazardously
Inappropriately stored, moved, or handled chemical tanks cars (trucks or train)
Spilled dry chemicals on floor between storage area and feed units
Improperly disposed of empty chemical containers
Large containers handled improperly, container transfer equipment not maintained
• No appropriate sized berms or dikes at liquid chemical feed units
• Inadequate supply of chemicals
• Chemical dust covering feed unit area or storage and transfer areas
• Use of an inappropriate coagulant
• Improperly stored or handled glass carboys (acid storage).
General Housekeeping
• Facility control panel in disrepair or not in use
• Wastewater pipelines not clearly distinguished from product pipelines
• Spills or leaks in dry areas not remediated in a timely manner.
Production Changes
Industries frequently make production changes because of advances in technology and
availability of new products. Therefore, during the tour of an industrial facility, the inspector
also should inquire about the following:
• Whether a permittee has made any changes to:
- Production processes
- Raw materials
- Amount of finished product
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Chapter Four Facility Site Review
- Water use
- Water reuse or recycling
- Waste treatment processes
- Other such changes
• Whether the permittee has modified any production process that would change the
pollutant types or loadings
• Whether the regulatory agency (EPA, State, or local municipality as appropriate) was
notified of such changes
• What changes will need to be reflected in any National Pollutant Discharge Elimination
System (NPDES) or local permit modifications.
The inspector should verify any changes and include the results of the findings and other
pertinent information in the Compliance Inspection Report. Changes in the loading to Publicly
Owned Treatment Works (POTWs) by the addition of a significant industrial discharger or
large population growth also should be ascertained and reported.
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4. FACILITY SITE REVIEW
C. Operation and Maintenance
Evaluation
Operation Evaluation
Operating factors affecting plant performance range from qualitative factors such as the skills
and aptitudes of operators (e.g., process knowledge and general aptitude), to physical
deficiencies in laboratory equipment or a lack of flexibility in process equipment. The
evaluation of operation functions must focus on wastewater treatment, sludge treatment/
disposal, and laboratory analysis. The evaluation should be based on the following topics:
• Policies and procedures
• Organization
• Staffing
• Planning
• Management controls.
Table 4-1 presents the basic review questions that an inspector should ask in evaluating
operation functions. Although each of the preceding evaluation topics must be covered in the
review of operation functions, the four areas discussed in the following paragraphs should
particularly concern the inspector:
Policies and Procedures
Written operating procedures and standard reference texts enable the operator to achieve
efficient plant operation. The operations manual prepared for the facility is the most important
reference that an inspector should review when evaluating plant policies and procedures.
Other reference materials relating to operations that should be available to the operator
include manufacturers' literature, publications by professional organizations (e.g., the Water
Environment Federation), and EPA publications.
Staffing
Even the best engineered facility cannot perform to its potential without a sufficient number of
capable and qualified staff. The inspector must consider the abilities and limitations of the
operating staff. Staff interviews may include the individual in charge of overall operation, the
chief operator, specific unit process operators, and laboratory staff.
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Chapter Four Facility Site Review
Health and Safety
At all times, safe operating procedures should be followed. Employees must be trained in
emergency shut-down, fire control, and spill response procedures, as well as in the use of
safety equipment, safe sampling techniques, and safe handling of chemicals and wastes.
Employees also should not enter confined spaces unless properly trained and equipped.
Managers must be aware of the Occupational Safety and Health Administration (OSHA)
Right-to-Know laws regarding potentially dangerous chemicals in the workplace. This law
specifically requires a written hazard communication program, labeling of chemicals, and the
availability of material safety data sheets to employees upon request.
Management Controls
Monitoring practices are a good indicator of both the emphasis placed on operations and the
operator's understanding of process controls. Factors affecting a facility's monitoring
capabilities are:
• The sampling program
• Performance testing
• Analytical capabilities
• Recordkeeping practices.
An effective process control program is essential to a treatment facility's optimal performance.
However, process control cannot be easily quantified by the inspector. In most cases, the
inspector must rely on discussions with the plant superintendent and/or operators to
supplement available records and the technical evaluation. The key considerations for
effective process controls are:
Process control data
Process knowledge of the operators
The basis for the control practices
Implementation of the control practices
Past performance
Operator emphasis on controls
Recordkeeping.
Maintenance Evaluation
Facility maintenance directly affects the ability of the facility to run efficiently and to comply
with its NPDES permit. The two types of facility maintenance are preventive maintenance and
corrective maintenance:
• Preventive maintenance
- Reduces facility operating costs by eliminating breakdowns and the need for
corrective maintenance
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Chapter Four Facility Site Review
- Improves the facility's reliability by minimizing the time equipment is out of service
- Increases the useful life of equipment, thus avoiding costly premature replacement
- Avoids possible compliance violations.
• Corrective maintenance
- Returns malfunctioning equipment to operation
- Avoids or minimizes possible compliance violations.
Evaluation of the maintenance function must focus on the ability to maintain process
equipment, supply of treatment chemicals, vehicles, and building and grounds. Although each
of the five evaluation topics (policies and procedures, organization, staffing, planning, and
management controls) must be covered for each facility inspected, the principal areas of
concern in the operations evaluation are the same in the maintenance function:
Staffing and training
Planning and scheduling
Management control—records systems and inventory control.
Only well-trained, competent plant staff can be expected to perform adequate physical
inspections, repairs, and preventive maintenance. Wastewater facility maintenance is complex
and requires a variety of skills. Because many of these skills are not readily available, an
ongoing training program is essential.
Maintenance planning and scheduling are essential to effective corrective and preventive
maintenance. The maintenance supervisor must prepare work schedules listing job priorities,
work assignments, available personnel, and timing.
A detailed records system is the basis of any maintenance program. Records are used to
establish maintenance histories on equipment, diagnose problems, and anticipate—and
thereby avoid—equipment failure, making records an effective tool for preventive
maintenance.
A central inventory of spare parts, equipment, and supplies must be maintained and
controlled. The basis for the inventory should be the equipment manufacturer's
recommendations, supplemented by specific, historical experience with maintenance problems
and requirements. Inventoried supplies must be kept at levels sufficient to avoid process
interruptions.
A maintenance cost control system should be an integral part of every wastewater facility.
Budgets must be developed from past cost records and usually are categorized according to
preventive maintenance, corrective maintenance, and projected and actual major repair
requirements. Annual costs must be compared to the budget periodically to control
maintenance expenditures. Evaluating costs this way serves to control expenditures and
provides a baseline for future budgets.
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Chapter Four Facility Site Review
The basic concerns that need to be addressed and evaluated during the inspector's
maintenance program review are presented in Table 4-1. These questions may help identify
the causes of a facility's operation and maintenance problems.
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Chapter Four Facility Site Review
Table 4-1
Operation and Maintenance Function Evaluation Questions
Policies and Procedures
• Is there a formal or informal set of policies for facility operations?
• Do policies address:
- Remaining in compliance?
- Maintaining process controls?
- Quality control?
- Preventive maintenance?
• Is there a set of standard procedures to implement these policies?
• Are the procedures written or informal?
• Do the procedures consider the following areas?
- Safety - Collection system
- Emergency - Pumping stations
- Laboratory - Treatment process
- Process control - Sludge disposal
- Operating procedures - Equipment record system
- Monitoring - Maintenance planning and
- Labor relations scheduling
- Energy conservation - Work orders
- Treatment chemical supply - Inventory management
• Are the procedures followed?
Organization
• Is there an Organizational Plan (or Chart) for operations?
• Does the Plan include:
- Delegation of responsibility and authority
- Job descriptions
- Interaction with other functions (such as maintenance)?
• Is the Plan formal or informal?
• Is the Plan available to and understood by the staff?
• Is the Plan followed?
• Is the Plan consistent with policies and procedures?
• Is the Plan flexible? Can it handle emergency situations?
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Chapter Four Facility Site Review
Table 4-1
Operations and Maintenance Function Evaluation Questions
(Continued)
Does the Plan clearly define lines of authority and responsibility in the following
subfunctional areas?
- Laboratory - Monitoring practices
- Process control - Mechanical
- Instrumentation - Electrical
- Sludge disposal - Buildings and grounds
- Collection system - Automotive
- Pumping stations - Supplies and spare parts?
Staffing
Is there an adequate number of staff to achieve policies and procedures?
Are staff members adequately qualified for their duties and responsibilities by
demonstrating the following:
- Certification
- Qualifications
- Ability
- Job performance
- Understanding of treatment processes
Is staff effectively used?
Has the potential for borrowing personnel been considered?
Are training procedures followed for:
- Orientation of new staff?
- Training new operators?
- Training new supervisors?
- Continuing training of existing staff?
- Cross training?
Which of the following training procedures are used?
- Formal classroom
- Home study
- On-the-job training
- Participation in professional organization
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Chapter Four Facility Site Review
Table 4-1
Operations and Maintenance Function Evaluation Questions
(Continued)
Does the training program provide specific instruction for the following operations and
maintenance activities?
- Safety - Emergency procedures
- Laboratory procedures - Mechanical
- Treatment processes - Electrical
- Instrumentation - Automotive
- Equipment troubleshooting - Building maintenance
- Handling personnel problems - Inventory control
- Monitoring practices
Does management encourage staff motivation?
Does management support its first-line supervisors?
Is staff motivation maintained through any of the following tools?
- Encouragement for training - Salary incentives
- Job recognition - Job security
- Promotional opportunities - Working environment
Operations
• How are operating schedules established?
• Do schedules attempt to attain optimum staff utilization?
• Are line supervisors included in manpower scheduling?
• Are staff involved in and/or informed of manpower planning?
• Is there sufficient long-term planning for staff replacement and system changes?
• Are there procedures in manpower staffing for emergency situations?
• How are process control changes initiated?
• How do process control changes interact with management controls?
• How effectively are laboratory results used in process control?
• Are there emergency plans for treatment control?
• Is there an effective energy management plan? Is the plan used?
• To what extent are operations personnel involved in the budget process?
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Chapter Four Facility Site Review
Table 4-1
Operations and Maintenance Function Evaluation Questions
(Continued)
Do budgets adequately identify and justify the cost components of operations?
Are future budgets based on current and anticipated operating conditions?
Do operating and capital budget limits constrain operations?
Can budget line items be adjusted to reflect actual operating conditions?
Maintenance
• Are maintenance activities planned? Is the planning formal or informal?
• Does the facility have sufficient management controls to affect realistic planning and
scheduling? If the controls exist, are they used?
• Are operating variables exploited to simplify maintenance efforts?
• To what extent are the supply and spare part inventories planned in conjunction with
maintenance activities?
• Have minimum and maximum levels been established for all inventory items?
• Does the facility have a maintenance emergency plan?
• Is the maintenance emergency plan current? Is the staff knowledgeable about
emergency procedures?
• Does a plan exist for returning to the preventive maintenance mode following an
emergency?
• Are preventive maintenance tasks scheduled in accordance with manufacturers'
recommendations?
• Is adequate time allowed for corrective maintenance?
• Are basic maintenance practices (preventive and corrective) and frequencies
reviewed for cost-effectiveness?
• Do the management controls provide sufficient information for accurate budget
preparation?
• Does the maintenance department receive feedback on cost performance to facilitate
future budget preparation?
• To what extent are maintenance personnel involved in the budget process?
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Chapter Four Facility Site Review
Table 4-1
Operations and Maintenance Function Evaluation Questions
(Continued)
• Do budgets adequately identify and justify the cost components of maintenance?
• Are future budgets based on current and anticipated operating and maintenance
conditions?
• Do maintenance and capital budget limits constrain preventive maintenance
(equipment replacement and improvements)?
• Does the maintenance department receive adequate feedback on cost performance?
• Can budget line items be adjusted to reflect actual maintenance conditions?
Management Controls
• Are current versions of the following documents maintained?
- Operating reports
- Work schedules
- Activity reports
- Performance reports (labor, supplies, energy)
- Expenditure reports (labor, supplies, energy)
- Cost analysis reports
- Emergency and complaint calls
- Process control data, including effluent quality
• Do the reports contain sufficient information to support their intended purpose?
• Are the reports usable and accepted by the staff?
• Are the reports being completed as required?
• Are the reports consistent among themselves?
• Are the reports used directly in process control?
• Are the reports reviewed and discussed with operating staff?
• What type of summary reports are required?
* To whom are reports distributed and when?
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Chapter Four Facility Site Review
Table 4-1
Operations and Maintenance Function Evaluation Questions
(Continued)
Management Controls (Maintenance)
Does a maintenance record system exist? Does it include the following?
- As-built drawings
- Shop drawings
- Construction specifications
- Capital and equipment inventory
- Maintenance history (preventive and corrective)
- Maintenance costs
Is the base record system kept current as part of daily maintenance practices?
Is there a work order system for scheduling maintenance? Is it explicit or implicit?
Which of the following do work orders contain?
- Date
- Location
- Work requirements
- Assigned personnel
- Work order number
- Nature of problem
- Time requirements
- Space for reporting work performed, required supplies, time required, and cost
summary
- Responsible staff member and supervisory signature requirements
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Chapter Four Facility Site Review
Table 4-1
Operations and Maintenance Function Evaluation Questions
(Continued)
• When emergency work must be performed without a work order, is one completed
afterward?
• Are work orders usable and acceptable by staff as essential to the maintenance
program? Are they actually completed?
• Is work order information transferred to a maintenance record system?
• Does a catalog or index system exist for controlling items in inventory?
• Are withdrawal tickets used for obtaining supplies from inventory?
• Do the tickets contain cost information and interact well with inventory controls and
the work order system?
• Is the cost and activity information from work orders aggregated to provide
management reports? Is this information also used for budget preparation?
• Is the maintenance performance discussed regularly with staff?
• How is the cost of contract maintenance or the use of specialized assistance
recorded?
• Are safeguards and penalties adequate to prevent maintenance cards from being
returned without the work being done?
• Is the preventive maintenance record checked after an emergency equipment'
failure?
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Chapter Four Facility Site Review
NOTES
4-26
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4. FACILITY SITE REVIEW
D. References and Facility Site Review
Checklist
References
U.S. Environmental Protection Agency. 1973. Maintenance Management Systems for
Municipal Wastewater Facilities. EPA 430/9-74-004.
U.S. Environmental Protection Agency. 1978. Field Manual for Performance Evaluation and
Troubleshooting at Municipal Wastewater Treatment Facilities. MO No. 16, EPA
430/9-78-001.
U.S. Environmental Protection Agency. 1979. Inspector's Guide for Evaluation of Municipal
Wastewater Treatment Plants. EPA 430/9-79-010.
U.S. Environmental Protection Agency. 1982. Comprehensive Diagnostic Evaluation and
Selected Management Issues. EPA 430/9-82-003.
Water Pollution Control Federation (WPCF). 1990. Operation of Wastewater Treatment
Plants. MOP No. 11, WPCF, 1990.
Water Environment Federation (WEF). 1992. Wastewater Treatment Plant Design. MOP No.
8, WEF, 1992.
4-27
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Chapter Four
Facility Site Review
FACILITY SITE REVIEW CHECKLIST
A. OPERATION AND MAINTENANCE EVALUATION
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1. Treatment units are properly operated and maintained.
2. Standby power or other equivalent provision is provided.
3. Adequate alarm system for power or equipment failures is available.
4. Sludge disposal procedures are appropriate:
a. Disposal of sludge according to regulations
b. State approval for sludge disposal received.
5. All treatment units, other than backup units, are in service.
6. Procedures for facility operation and maintenance are followed.
7. Sufficient sludge is disposed of to maintain treatment process
equilibrium.
8. Organizational Plan (chart) for operation and maintenance is
provided.
9. Operating schedules are established.
10. Emergency plan for treatment control established.
11. Maintenance record system exists and includes:
a. As-built drawings
b. Shop drawings
c. Construction specifications
d. Maintenance history
e. Maintenance costs
f. Repair history
g. Records of equipment repair and timely return to service.
12. Adequate number of qualified operators on-hand.
13. Established procedures are available for training new operators.
14. Adequate spare parts and supplies inventory are maintained.
15. Instruction files are kept for operation and maintenance of each
item of major equipment.
16. Operation and maintenance manual is available.
17. Regulatory agency is notified of any bypassing.
(Dates )
18. a. Hydraulic overflows and/or organic overloads are
experienced.
b. Untreated bypass discharge occurs during power failure.
c. Untreated overflows occurred since last inspection.
Reason:
d. Flows were observed in overflow or bypass channels.
e. Checking for overflows is performed routinely.
f. Overflows are reported to EPA or to the appropriate State
agency as specified in the permit.
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Chapter Four
Facility Site Review
FACILITY SITE REVIEW CHECKLIST
(Continued)
B. SAFETY EVALUATION
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1. Undiked oil/chemical storage tanks are used at facility:
2. Up-to-date equipment repair records ARE maintained.
3. Dated tags show out-of-service equipment.
4. Routine and preventive maintenance is scheduled/performed on
time.
5. Personal protective clothing is provided (safety helmets, ear
protectors, goggles, gloves, rubber boots with steel toes,
eyewashes in labs).
6. Safety devices are readily available:
a. Fire extinguishers
b. Oxygen deficiency/explosive gas indicator
c. Self-contained breathing apparatus near entrance to chlorine
room
d. Safety harness
e. First aid kits
f. Ladders to enter manholes or wetwells (fiberglass or
wooden for electrical work)
g. Traffic control cones
h. Safety buoy at activated sludge plants
i. Life preservers for lagoons
Fiberglass or wooden ladder for electrical work
Portable crane/hoist.
J-
k.
7. Plant has general safety structures such as rails around or covers
over tanks, pits, or wells.
8. Emergency phone numbers are listed, including EPA and State.
9. Plant is generally clean, free from open trash areas.
10. Portable hoists, for equipment removal, are available.
11. All plant personnel are immunized for typhoid and tetanus.
12. No cross connections exist between a potable water supply and
nonpotable source.
13. Gas/explosion controls such as pressure-vacuum relief values, no
smoking signs, explosimeters, and drip traps are present near
anaerobic digesters, enclosed screening or degritting chambers,
and sludge-piping or gas-piping structures.
14. All electrical circuitry is enclosed and identified.
15. Personnel are trained in electrical work to be performed as well as
safety procedures.
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Chapter Four
Facility Site Review
FACILITY SITE REVIEW CHECKLIST
(Continued)
B. SAFETY EVALUATION (Continued)
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
16. Chlorine safety precautions are followed:
a. NIOSH-approved 30-minute air pack
b. All standing chlorine cylinders chained in place
c. All personnel trained in the use of chlorine
d. Chlorine repair kit available
e. Chlorine leak detector tied into plant alarm system
f. Chlorine cylinders stored in adequately ventilated areas?
g. Ventilation fan with an outside switch
K.Posted safety precautions.
17. Facility has complied with the six employer responsibilities for the
Worker Right-to-Know Law (P.A. 83-240)
18. Emergency Action Plan on file with local fire department and
appropriate emergency agency.
19. Laboratory safety devices (eyewash and shower, fume hood,
proper labeling and storage, pipette suction bulbs) available.
20. Warning signs (no smoking, high voltage, non potable water,
chlorine hazard, watch-your-step, and exit) posted.
4-30
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5. SAMPLING
Contents Page
A. Evaluation of Permittee Sampling Program and Compliance Sampling
Objectives and Requirements 5-1
Significant Industrial User Monitoring Program 5-2
B. Sampling Procedures and Techniques
Sample Collection Techniques 5-3
EPA Sample Identification Methods 5-7
Sample Preservation and Holding Time 5-7
Transfer of Custody and Shipment of Samples 5-8
Quality Control 5-9
Data Handling and Reporting 5-9
C. References and Permittee Sampling Inspection Checklist
References 5-25
Permittee Sampling Inspection Checklist 5-27
List of Tables
5-1 Volume of Sample Required for Determination ofthe Various Constituents of
Industrial Wastewater 5-11
5-2 Compositing Methods 5-13
5-3 Required Containers, Preservation Techniques, and Holding Times 5-14
5-4 Quality Control Procedures for Field Analysis and Equipment 5-21
Associated Appendices
F Example Chain-of-Custody Form
5-i
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Chapter Five Contents
NOTES ***
5-ii
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5. SAMPLING
A. Evaluation of Permittee Sampling
Program and Compliance Sampling
Wastewater sampling/analysis is an integral part of the National Pollutant Discharge
Elimination System (NPDES) Compliance Monitoring Program. NPDES permits contain
specific and legally enforceable effluent limitations and monitoring requirements.
Objectives and Requirements
When evaluating the permittee sampling program, the inspector should:
• Verify that the permittee's sampling program complies with the permit
• Verify that the permittee's sampling program complies with 40 Code of Federal
Regulations (CFR) Parts 136.1 to 136.5 and Appendices A, B, and C (Guidelines for
Establishing Test Procedures for the Analysis of Pollutants)
• Document violations to support enforcement action.
In addition, specific objectives of the sampling conducted by inspectors include the following:
Verify compliance with daily maximum effluent limitations
Verify accuracy of reports and program self-monitoring
Support enforcement action
Support permit development reissuance and/or revision
Determine the quantity and quality of effluent.
Sampling, analysis, preservation technique, sample holding time, and sample container
requirements are provided under 40 CFR Part 136 as authorized by Section 304(h) of the
Clean Water Act (CWA). More information on required analytical procedures can be found
under "Laboratory Analyses Techniques Evaluation" in Chapter Seven. A checklist for use in
evaluating the permittee's sampling program is located at the end of this chapter.
For all NPDES permittees, an evaluation of the permittee sampling program should include a
review of sampling procedures used by the facility and of quality control measures used to
ensure the integrity of sample data.
Evaluation of sampling procedures should include an assessment of the following six areas:
• Sample collection techniques
• Sample identification
5-1
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Chapter Five Sampling
Sample preservation and holding time
Transfer of custody and shipment of samples
Quality control
Data handling and reporting.
Significant Industrial User Monitoring Program
It is the responsibility of the permitted Publicly Owned Treatment Works (POTW) with a
pretreatment program to oversee sampling procedures of industrial users and to conduct
compliance monitoring of its own. Therefore, during a Pretreatment Compliance Inspection
(PCI) or audit, the inspector may also need to evaluate POTW sampling procedures for
significant industrial users who discharge to the POTW in addition to evaluating the sampling
procedures of any permitted POTW. According to the General Pretreatment Regulations, 40
CFR 403.12(0), industrial users and POTWs subject to 40 CFR 403.12 reporting requirements
must maintain the following monitoring records:
• Date, exact place, method and time of sampling, and name of sampler
• Date of analysis
• Name of analyst
• Analytical techniques/methods used
• Analytical results.
During a PCI or an audit, the inspector evaluates the POTW industrial user monitoring
program with respect to the criteria specified in the POTW pretreatment program. Elements of
the sampling scheme will include the six areas addressed above and any other areas
specifically addressed in the particular pretreatment program. Chapter Nine, "Pretreatment,"
discusses the focus of this evaluation in greater detail.
5-2
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5. SAMPLING
B. Sampling Procedures and
Techniques
Whether an inspector is evaluating a permittee's sampling program or conducting compliance
sampling on the permittee's effluent, that inspector must be familiar with the procedures and
techniques necessary for accurate sampling of wastewaters. The following discussion details
the procedures for sample collection, preservation, transfer, quality control, and data handling.
Sample Collection Techniques
Sample collection is an important part of the compliance monitoring program. Without proper
sample collection procedures, the results of such monitoring programs are neither useful nor
valid, even with the most precise and accurate analytical measurements.
Selection of Representative Sampling Sites
Samples should be collected at the location specified in the permit. In some instances, the
sampling location specified in the permit or the location chosen by the permittee may not be
adequate for the collection of a representative sample. In that case, the inspector should
determine the most representative sampling point available and collect a sample at both
locations. The reason for the conflict must be documented for later resolution by the
permitting authority.
Influent Samples. These samples should be taken at points of high turbulence flow to ensure
good mixing. In some instances, the most desirable location may not be accessible.
Sampling points always should be above plant return lines, and sampling equipment should
be placed so that it does not interfere with flow measuring devices. The preferred sampling
points for raw wastewater are:
• Waste flowing from last process in a manufacturing operation
• Pump wet well (if turbulent)
• Upstream collection lines, tank, or distribution box following pumping from the wet well
or sump
• Flume throat
5-3
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Chapter Five Sampling
• Aerated grit chamber
• Upstream siphon following the comminutor (in absence of grit chamber).
If it is not possible to sample at a preferred point, an alternative location should be chosen
and the basis for choosing that location must be documented.
Effluent Samples. These samples should be collected at the site specified in the permit or, if
no site is specified in the permit, at the most representative site downstream from all entering
wastestreams before they enter the receiving waters. For most municipal plants, samples
should be collected after chlorination. Occasionally, municipal plant permits may specify
sampling prior to chlorination. For these plants, all parameters can be monitored at the
upstream location except fecal coliforms, pH, and total residual chlorine. Wastewater for use
in bioassays should be collected at the location specified in the facility's NPDES permit.
Samples can be collected either manually (grab or composite) or with automatic samplers
(continuous or composite). The following general guidelines apply when taking samples:
• Take samples at a site specified in the NPDES permit and/or at a site selected to yield
a representative sample.
• Use a sampling method (grab, composite, continuous) as required in the permit. Some
parameters that are not to be collected by automatic samplers, but must be hand
collected are dissolved oxygen, total residual chlorine, oil and grease, coliforms,
purgeable organics, sulfides, cyanide, and total phenols.
• Avoid collecting large nonhomogeneous particles and objects.
• Collect the sample facing upstream to avoid contamination.
• Do not rinse sample container with sample when collecting oil and grease and
microbiological samples, but fill it directly to within 2.5 to 5 cm from the top.
• Fill the container completely if the sample is to be analyzed for purgeable organics,
oxygen, ammonia, hydrogen sulfide, free chlorine, pH, hardness, sulfite, ammonium,
ferrous iron, acidity, or alkalinity.
• Collect sufficient volume to allow for quality assurance testing. (Table 5-1 provides a
guide to numerous sample volumes, but additional volumes may be necessary for
quality assurance testing.)
Sample Types
Two types of sample techniques are used: grab and composite. For many monitoring
procedures, the sample type is not specified in 40 CFR Part 136. For these procedures, the
NPDES permit writer determines the appropriate sample type and specifies them in the
NPDES permit.
5-4
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Chapter Five Sampling
Grab Samples. Grab samples are individual samples collected over a period of time not
exceeding 15 minutes and are representative of conditions at the time the sample is collected.
The sample volume depends on the type and number of analyses to be performed. The
collection of a grab sample is appropriate when a sample is needed to:
• Sample an effluent discharge that is not on a continuous basis
• Provide information about instantaneous concentrations of pollutants at a specific time
• Allow collection of a variable sample volume
• Corroborate composite samples
• Monitor parameters not amenable to compositing (e.g., pH, temperature, dissolved
oxygen, chlorine, purgeable organics, oil and grease, coliform bacteria, and others
specified by the NPDES permit, which may include phenols, sulfites, and hexavalent
chromium). Volatile organics, sulfides, phenols, and phosphorus samples can be
composited but require special handling procedures.
Composite Samples. These samples are collected over time, either by continuous sampling
or by mixing discrete samples, and represent the average characteristics of the wastestream
during the compositing period. Composite samples are used when stipulated in a permit and
when:
• Average pollutant concentration during the compositing period is determined
• Mass per unit time loadings is calculated
• Wastewater characteristics are highly variable.
Various methods for compositing samples are available and are based on either time or flow
proportioning. Table 5-2 lists the advantages and disadvantages of various methods. The
permit may specify which type of composite sample to use. Composite samples can be
collected either manually or with automatic samplers. Inspectors should consider variability in
wastestream flow rate and parameter concentrations carefully when choosing compositing
methods, sampling equipment (tubing and containers), and quality assurance procedures.
The compositing methods are as follows:
• Time Composite Sample—This method requires discrete sample aliquots collected in
one container at constant time intervals. This method is appropriate when the flow of
the sampled stream is constant (flow rate does not vary more than ±10 percent of the
average flow rate) or when flow monitoring equipment is not available.
• Flow-Proportional Composite Sample—There are two methods used for this type of
sample. One method collects a constant sample volume at varying time intervals
proportional to stream flow (e.g., 200 milliliters sample collected for every 5,000 gallons
of flow). In the other method, the sample is collected by increasing the volume of each
aliquot as the flow increases, while maintaining a constant time interval between the
aliquots.
5-5
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Chapter Five Sampling
Sequential Composite Sample—This method requires discrete samples collected in
individual containers at constant time intervals or discharge increments—for example,
samples collected every 15 minutes, composited into separate containers each hour.
The discrete samples can then be manually flow-proportioned to form the composite
sample. Alternatively, a constant sample volume is taken at constant discharge
increments, as measured with a totalizer.
Continuous Composite Sample—This example must be collected continuously from the
wastestream. The sample may be constant volume, or the volume may vary in
proportion to the flow rate of the wastestream.
Sample Volume
The volume of samples collected depends on the type and number of analyses needed, as
reflected in the parameters to be measured. The volume of the sample obtained should be
sufficient for all the required analyses plus an additional amount to provide for any split
samples or repeat analyses. Table 5-1 provides a guide to sample volumes required for
determining the constituents in wastewater. The laboratory receiving the sample should be
consulted for any specific volume required. Specific recommended minimum sample volumes
for different pollutant parameters can be found in EPA's Methods for Chemical Analysis of
Water and Wastes (USEPA 1979b) and Handbook for Sampling and Sample Preservation of
Water and Wastewater (USEPA 1982), and the current Environmental Protection Agency
(EPA)-approved edition of Standard Methods for the Examination of Water and Wastewater
[American Public Health Association (APHA), American Water Works Association (AWWA),
and Water Environment Federation (WEF)].
Sample Containers
Required sample containers, sample preservation, and sample holding time are described in
40 CFR Part 136. Table 5-3 includes this material. It is essential that the sample containers
be made of chemically resistant material unaffected by the concentrations of the pollutants
measured. In addition, sample containers must have a closure that will protect the sample
from contamination. Wastewater samples for chemical analysis generally are collected in
plastic (polyethylene) containers. Exceptions to this general rule are oil and grease samples,
pesticides, phenols, Polychlorinated Biphenyls (PCBs), and other organic pollutant samples.
These are collected in properly cleaned glass jars or bottles and sealed. Bacteriological
samples always are collected in properly sterilized plastic or glass containers. Samples that
contain constituents that will oxidize when exposed to sunlight (such as iron cyanide
complexes) should be collected in dark containers.
Sample containers should be clean and uncontaminated. Some analytical procedures specify
container cleaning procedures to be followed. Precleaned and sterilized disposable containers
can be used (e.g., polyethylene cubitainers). If these are not used or if the analytical method
does not specify procedures, the following procedures for cleaning sample containers can
generally be used:
5-6
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Chapter Five Sampling
• Wash with hot water and detergent.
• Rinse with acid (e.g., nitric for metals).
• Rinse with tap water, then rinse three or more times with organic-free water.
• Rinse glass containers with an interference-free, redistilled solvent (such as acetone or
methylene chloride for extractable organics).
• Dry in contaminant-free area.
EPA Sample Identification Methods
Each sample must be accurately and completely identified. Any label or tag used to identify
the sample must be moisture-resistant and able to withstand field conditions. A waterproof
pen should be used to complete the labels or tags. A numbered label or tag associated with
a field sample data sheet containing detailed information on the sample is preferable to using
only a label or tag for information. The information provided for each sample should include
the following:
• Facility name/location
• Sample site location
• Sample number
• Name of sample collector
• Date and time of collection
• Indication of grab or composite sample with appropriate time and volume information
• Identification of parameter to be analyzed
• Preservative used.
Sample Preservation and Holding Time
In most cases, wastewater samples contain one or more unstable pollutants that require
immediate preservation and/or analysis. Appropriate chemical preservation should be
provided before samples are transferred to the laboratory. Procedures used to preserve
samples include cooling, pH adjustment, and chemical treatment. For some parameters such
as cyanide and phenols, preservatives must be added to sample bottles prior to or
immediately following sample collection. For many samples, if preservatives are not
appropriately used, bacteria can quickly degrade certain constituents (such as phenols and
phosphorus). 'Other constituents may volatilize (such as volatile organics and sulfides) or may
5-7
-------
Chapter Five - Sampling
react to form different chemical species (hexavalent chromium, for example). Proper
preservation and holding times are essential to ensure sample integrity. (See Table 5-3 and
refer to 40 CFR Part 136.)
Prompt analysis is the most positive assurance against error from sample deterioration, but
prompt analysis is not feasible for composite samples in which portions may be stored for as
long as 24 hours. Where possible, sample preservation must be provided during compositing,
usually by refrigeration to 4°C (or icing). If an automatic sampler is used with ice, the ice
must be replaced as necessary to maintain low temperatures. This is a particular limitation of
automatic samplers used during the summer when ice must be frequently replaced.
Maximum sample holding times are also indicated in 40 CFR Part 136. Times listed are the
maximum holding times between sample collection and analysis that are allowed for the
sample to be considered valid. Typically, the holding time limitations begin upon combination
of the last aliquot in a sample.
Transfer of Custody and Shipment of Samples
To ensure the validity of the permit compliance sampling data in court, written records must
accurately trace the custody of each sample through all phases of the monitoring program.
The primary objective of this chain-of-custody is to create an accurate written record (see
Appendix F, an example chain-of-custody form) that can be used to trace the possession and
handling of the sample from the moment of its collection through its analysis and introduction
as evidence.
• Sample seals should be used to protect the sample's integrity from the time it is
collected to the time it is opened in the laboratory. The seal should indicate the
collector's name, the date and time of sample collection, and sample identification
number.
• Samples should be packed properly to prevent breakage. The shipping container
should be sealed or locked so that any evidence of tampering can be readily detected.
Use of tamperproof evidence tape is recommended.
• Samples should be placed on ice or synthetic ice substitute that will maintain sample
temperature at 4°C throughout shipment.
• Every sample must be accompanied by a sample tag and a chain-of-custody record
that has been completed, signed, and dated. The chain-of-custody record should
include the names of sample collectors, sample identification numbers, date and time
of sample collection, location of sample collection, and names and signatures of all
persons handling the sample in the field and in the laboratory.
• The responsibility for proper packaging, labeling, and transferring of possession of the
sample lies with the person taking it.
5-8
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Chapter Five Sampling
All sample shipments must be accompanied by the chain-of-custody record and other
pertinent forms. A copy of these forms should be retained by the originator. Also, all
receipts associated with the shipment should be retained.
When transferring possession of samples, the transferee must sign and record the date
and time on the chain-of-custody record (use the currently approved record). In
general, custody transfers are made for each sample, although samples may be
transferred as a group, if desired. Each person who takes custody must fill in the
appropriate section of the chain-of-custody record.
Quality Control
Control checks should be conducted during the actual sample collection to determine the
performance of sample collection techniques. In general, the most common monitoring errors
usually are caused by improper sampling, improper preservation, inadequate mixing during
compositing and splitting, and excessive sample holding time. In addition, the following
samples should be collected and analyzed to check sample collection techniques:
• Duplicate samples are separate samples taken from the same source at the same
time. These samples provide a check on sampling equipment and precision
techniques.
• Split samples are samples that have been divided into two containers for analysis by
separate laboratories. These samples provide an excellent means of identifying
discrepancies in the permittee's analytical techniques and procedures.
The laboratories performing the sample analyses should also use the following quality control
measures:
• Spiked samples are samples to which a known quantity of substance has been added.
They provide a way to verify the accuracy of the analytical procedures.
• Sample preservative blanks are samples of distilled water to which a known quantity of
preservative is added. They are analyzed to determine the effectiveness of the
preservative, providing a check on the contamination of chemical preservatives.
Table 5-4 indicates quality control procedures for field analyses and equipment. Quality
control is discussed in greater detail in Chapter Seven of this manual and EPA's NPDES
Compliance Inspector Training Laboratory Analyses Manual, April 1990.
Data Handling and Reporting
Verified analytical results are normally entered into a laboratory data management system of
some type. The system should contain the sampling data, including time and exact location,
analysis dates and times, names of analysts, analytical methods/techniques used, and
analytical results. Data are then reported to the project officer (inspector) for inclusion into the
5-9
-------
Chapter Five Sampling
compliance report. The quality assurance manual by EPA (Handbook for Analytical Quality
Control in Water and Wastewater Laboratories, USEPA 1979) and the article by J.J. Delfino
("Quality Assurance In Water and Wastewater Analysis Laboratories," Delfino 1977) provide
useful information to the inspector on a number of data management techniques.
5-10
-------
Chapter Five Sampling
Table 5-1
Volume of Sample Required for Determination of
the Various Constituents of Industrial Wastewater
(Associated Water and Air Resource Engineers, Inc. 1973
Handbook for Monitoring Industrial Wastewater.
USEPA Technology Transfer.)
Tests Volume of Sample. (1) ml
PHYSICAL
Color and Odor(2) 100 to 500
Corrosivity(2) Flowing sample
Electrical conductivity(2) 100
pH, electrometric(2) 100
Radioactivity 100 to 1,000
Specific gravity(2) 100
Temperature(2) Flowing sample
Toxicity(2) 1,000 to 20,000
Turbidity(2) 100 to 1,000
CHEMICAL
Dissolved Gases:
Ammonia,(3) NH(3) 500
Carbon dioxide,(3) free C02 200
Chlorine,(3) free CL 200
Hydrogen,(3) H2 1,000
Hydrogen sulfide,(3) H2S 500
Oxygen,(3) O2 500 to 1,000
Sulfur dioxide,(3) free SO2 100
Miscellaneous:
Acidity and alkalinity 100
Bacteria, iron 500
Bacteria, sulfate-reducing 100
Biochemical oxygen demand (BOD) . 100 to 500
Carbon dioxide, total C02 (including C03~ HC03~, and free) 200
Chemical oxygen demand (dichromate) 50 to 100
Chlorine requirement 2,000 to 4,000
Chlorine, total residual CI2 (including OCr, HOCI,
NH2CI, NHCI2, and free) 200
Chloroform-extractable matter 1,000
Detergents 100 to 200
Hardness 50 to 100
Hydrazine 50 to 100
Microorganisms 100 to 200
Volatile and filming amines 500 to 1,000
Oily matter 3,000 to 5,000
Organic nitrogen 500 to 1,000
Phenolic compounds 800 to 4,000
pH, colorimetric 10 to 20
Polyphosphates 100 to 200
Silica 50 to 1,000
Solids, dissolved 100 to 20,000
Solids, suspended 50 to 1,000
Tannin and lignin 100 to 200
5-11
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Chapter Five Sampling
Table 5-1
Volume of Sample Required for Determination of
the Various Constituents of Industrial Wastewater
(Continued)
Tests Volume of Sample, (1) ml
Cations:
Aluminum, Ar*+ 100 to 1,000
Ammonium,(3) NH4* 500
Antimony, Sb^ to Sb+++++ 100 to 1,000
Arsenic, As+++ to As+++++ 100 to 1,000
Barium, Ba++ 100 to 1,000
Cadmium, CcT 100 to 1,000
Calcium, Ca++ 100 to 1,000
Chromium, Cr+++ to cr*++++ 100 to 1,000
Copper, Cu++ 200 to 4,000
lron,(3) Fe++ and Fe~+ 100 to 1,000
Lead, Pb++ 100 to 4,000
Magnesium, Mg~ 100 to 1,000
Manganese, Mn++ to Mnw++++ 100 to 1,000
Mercury, Hg+ and Hg^ 100 to 1,000
Potassium, K+ 100 to 1,000
Nickel, Ni++ 100 to 1,000
Silver, Ag+ 100 to 1,000
Sodium, Na+ 100 to 1,000
Strontium, Sr++ 100 to 1,000
Tin, Sn~ and Sn**** 100 to 1,000
Zinc, Zn++ 100 to 1,000
Anions:
Bicarbonate, HCO3~ 100 to 200
Bromide, Br~ 100
Carbonate, CO3~ 100 to 200
Chloride, C|— 25 to 100
Cyanide, Cn~ 25 to 100
Fluoride, Fl~ 200
Hydroxide, OH~ 50 to 100
Iodide, I- 100
Nitrate, NO3- 10 to 100
Nitrite, NO2— 50 to 100
Phosphate, ortho, PO4—, HPO4—, H2PO4- 50 to 100
Sulfate, SO4— HSO4 100 to 1,000
Sulfide, S—, HS- 100 to 500
Sulfite, S03—, HS03- 50 to 100
(1) Volumes specified in this table should be considered as guides for the approximate quantity of
sample necessary for a particular analysis. The exact quantity used should be consistent with
the volume prescribed in the standard method of analysis, whenever a volume is specified.
(2) Aliquot may be used for other determinations.
(3) Samples for unstable constituents must be obtained in separate containers, preserved as
prescribed; containers must be completely filled and sealed against air exposure.
5-12
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Chapter Five
Sampling
Table 5-2
Compositing Methods
Method
jWWsftW^^?
• Constant sample
volume, constant time
interval between
samples
M0^»c>fteiflBh^»6N
• Constant sample
volume, time interval
between samples
proportional to stream
flow
• Constant time interval
between samples,
sample volume
proportional to total
stream flow at time of
sampling
• Constant time interval
between samples,
sample volume
proportional to total
stream flow since last
sample
Sequential Composite •
• Series of short period
composites, constant
time intervals
between samples
• Series of short period
composites, aliquots
taken at constant
discharge increments
Continuous Composite
• Constant sample
volume
• Sample volume
proportional to stream
flow flows;
Advantages
^SfciSBV'*' ''^ ":": ;'.,,.'
Minimal instrumentation
and manual effort;
requires no flow
measurement
; ' „ . -=.
Minimal manual effort
Minimal instrumentation
Minimal instrumentation
:'• _ „/ « •
Useful if fluctuations
occur and time history is
desired
Useful if fluctuations
occur and the time
history is desired
^ ^<
Minimal manual effort,
requires no flow
measurement highly
variable flows
Minimal manual effort,
most representative
especially for highly
variable sample volume,
variable pumping
capacity and power
Disadvantages
,-. f „ i. *%•
May lack
representativeness,
especially for highly variable
flows
Requires accurate flow
measurement reading
equipment; manual
compositing from flowchart
Manual compositing from
flowchart in absence of prior
information on the ratio of
minimum to maximum flow;
chance of collecting too
small or too large individual
discrete samples for a given
composite volume
Manual compositing from
flow chart in absence of
prior information on the ratio
of minimum to maximum
flow; chance of collecting
either too small or too large
individual discrete samples
for a given composite
volume
Requires manual
compositing of aliquots
based on flow
Requires flow totalizer;
requires manual
compositing of aliquots
based on flow
Requires large sample
capacity; may lack
representativeness for
highly representative flows
Requires accurate flow
measurement equipment,
large sample volume,
variable pumping capacity,
and power
Comments
//••"' .„, • ^v^o*J?
Widely used in
both automatic
samplers and
manual handling
• •'•" **'/'' ^iSv:
Widely used in
automatic as well
as manual
sampling
Used in automatic
samplers and
widely used as
manual method
Not widely used in
automatic samplers
but may be done
manually
_--•*• ;? "" , -.;V*
Commonly used;
however, manual
compositing is
labor intensive
Manual
compositing is
labor intensive '
',, •*•'"- - "~ i" .
Practical but not
widely used
Not widely used
5-13
-------
Chapter Five
Sampling
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Chapter Five
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5-15
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Chapter Five
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Chapter Five
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Chapter Five
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Chapter Five
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Chapter Five
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Chapter Five
Sampling
Table 5-4
Quality Control Procedures for Field Analysis and Equipment
Parameter
General
Daily
Quarterly
B«iid%f^f§xyg|n'' ,,-*. '"•• ••,.••'
• Membrane
Electrode
• Winkler-Azide
method
Enter the make, model,
and serial and/or ID
number for each meter in
a logbook.
Report data to nearest
0.1 mg/l.
Record data to nearest
0.1 mg/l.
Calibrate meter using
manufacturer's instructions
or Winkler-Azide method.
Check membrane for air
bubbles and holes.
Change membrane and
KCI if necessary.
Check leads, switch
contacts, etc., for corrosion
and shorts if meter pointer
remains off-scale.
Duplicate analysis should
be run as a precision
check. Duplicate values
should agree within ±0.2
mg/l.
Check instrument
calibration and linearity
using a series of at
least three dissolved
oxygen standards.
Take all meters
to the laboratory
for maintenance,
calibration, and quality
control checks.
pJ*;i'J?'/ «,'"%':irw 7>4^%^;;*'' '•' ""'--..'", ' ' " ' :
• Electrode
Method
Enter the make, model,
and serial and/or ID
number for each meter in
a logbook.
Calibrate the system
against standard buffer
solutions of known pH
value (e.g., 4, 7, and 9 at
the start of a sampling
run).
Periodically check the
buffers during the sample
run and record the data in
the logbook.
Be on the alert for erratic
meter response arising
from weak batteries,
cracked electrodes, fouling,
etc.
Check response and
linearity following highly
acidic or alkaline samples.
Allow additional time for
equilibration.
Check against the closest
reference solution each
time a violation is found.
Rinse electrodes
thoroughly between
samples and after
calibration.
5-21
-------
Chapter Five
Sampling
Table 5-4
Quality Control Procedures for Field Analysis and Equipment
(Continued)
Parameter
General
Daily
Quarterly
Conductivity
Enter the make, model,
and serial and/or ID
number for each meter in
a logbook.
Standardize with KCI
standards having similar
specific conductance
values to those anticipated
in the samples. Calculate
the cell constant using two
different standards.
Rinse cell after each
sample to prevent
carryover.
Take all meters to lab
for maintenance,
calibration, and quality
control checks.
Check temperature
compensation.
Check date of last
platinizing, if necessary.
Analyze NITS or EPA
reference standard, and
record actual vs.
observed readings in
the logbook.
Residual Chlorine
Amperometric
Titration
Enter the make, model,
and ID and/or serial
number of each titration
apparatus in a logbook.
Report results to nearest
0.01 mg/l.
Refer to instrument
manufacturer's instructions
for proper operation and
calibration procedures.
Biweekly, return
instrument to lab for
maintenance and
addition of fresh,
standardize reagents.
Temperature
Manual
Enter the make, model,
and serial and/or ID
number and temperature
range.
Check for air spaces of
bubbles in the column,
cracks, etc. Compare with
a known source if
available.
Biweekly, check at two
temperatures against a
NITS or equivalent
thermometer. Enter
data in logbook.
5-22
-------
Chapter Five
Sampling
Table 5-4
Quality Control Procedures for Field Analysis and Equipment
(Continued)
Parameter
General
Daily
Quarterly
Temperature (Continued) '" - ";V-. •"""''" ~'%:; -,P*S^ -;;%»"* -W .^';1tj^:S|
• Thermistors,
Thermographs,
etc.
All standardization should
be against a traceable
NITS or NITS calibrated
thermometer. Reading
should agree within ±1°C.
If enforcement action
is anticipated, calibrate
the thermometer before
and after analysis. All
data should be read to
the nearest 1°C. Report
data between 1 0°
and 99°C to two
significant figures.
Enter the make,
model, and serial and/or
ID number of the
instrument in a logbook.
All standardization shall
be against a NITS or
NITS calibrated
thermometer. Reading
should agree within ±1°C.
If enforcement action is
anticipated, refer to the
procedure listed above.
Check thermistor and
sensing device for
response and operation
according to the
manufacturer's instruction.
Record actual vs. standard
temperature in logbook.
Temperature readings
should agree within
+1°Corthe
thermometer should
be replaced or
recalibrated.
Initially and biannually,
determine accuracy
throughout the expected
working range of 0°C to
50°C. A minimum of
three temperatures
within the range should
be used to verify
accuracy. Preferable
ranges are 5-1 0°C, 15-
25°C, and 35-45°C.
Initially and biannually,
determine accuracy
throughout the expected
working range of 0°C to
50°C. A minimum of
three temperatures
within the range should
be used to verify
accuracy. Preferable
ranges are 5-1 0°C, 15-
25°C, and 35-45°C.
Flow Measurement • ,_- ,,,-,:.i; ->.<„„, '* r ^,,,*-* ,-• ' •'• V- "" • -./•"":
Enter the make, model,
and serial and/or ID
number of each flow
measurement instrument
in a logbook.
Install the device in
accordance with the
manufacturer's instructions
and with the procedures
given in owner's manual.
Annually affix record of
calibration (NITS,
manufacturer) to the
instrument log.
Automatic Samplers . . • ••**• -.^ "^-: ^ ~\t?*"" -*• ; - '-"""^ ,,r,lV?"C
Enter the make, model,
and serial and/or ID
number of each sampler
in a logbook.
Check intake velocity
vs. head (minimum of
three samples), and
clock time setting vs.
actual time interval.
5-23
-------
Chapter Five Sampling
*** NOTES ***
5-24
-------
5. SAMPLING
C. References and Permittee Sampling
Inspection Checklist
References
APHA, AWWA, and WEF. Standard Methods for the Examination of Water and Wastewater.
(Use the most current, accepted edition.)
Associated Water and Air Resources Engineers, Inc. 1973. Handbook for Industrial
Wastewater Monitoring, USEPA Technology Transfer.
Code of Federal Regulations. 1985. Title 40, Part 136.31. Office of the Federal Register.
Delfino, J.J. 1977. "Quality Assurance in Water and Wastewater Analysis Laboratories."
Water and Sewage Works, 124(7): 79-84.
Federal Register, Vol. 49, No. 209, October 26, 1984. Guidelines Establishing Test
Procedures for the Analysis of Pollutants Under the Clean Water Act; Final Rule and Interim
Final Rule and Proposed Rule.
Harris, D.J., and Keffer, W.J. 1974. Wastewater Sampling Methodologies and Flow
Measurement Techniques. U.S. Environmental Protection Agency Region VII, EPA-907/
9-74-005, Kansas City, Missouri.
Lauch, R.P. 1975. Performance of ISCO Model 1391 Water and Wastewater Sampler. U.S.
Environmental Protection Agency, EPA-670/4-75-003, Cincinnati, Ohio.
Lauch, R.P. 1976. A Survey of Commercially Available Automatic Wastewater Samplers.
U.S. Environmental Protection Agency, EPA-600/4-76-051, Cincinnati, Ohio.
Shelley, P.E. 1975. Design and Testing of a Prototype Automatic Sewer Sampling System.
Office of Research and Development, U.S. Environmental Protection Agency, EPA 600/
2-76-006, Washington, D.C.
Shelley, P.E., and Kirkpatrick, G.A. 1975. An Assessment of Automatic Sewer Flow
Samplers. Office of Research and Development, U.S. Environmental Protection Agency,
EPA-600/2-75-065, Washington, D.C.
U.S. Environmental Protection Agency. 1978. Methods for Benzidine, Chlorinated Organic
Compounds, Pentachlorophenol and Pesticides in Water and Wastewater. Environmental
Monitoring and Support Laboratory, Cincinnati, Ohio.
5-25
-------
Chapter Five Sampling
U.S. Environmental Protection Agency. 1979a. Handbook for Analytical Quality Control in
Water and Wastewater Laboratories. EPA-600/4-79-019.
U.S. Environmental Protection Agency. 1979b. Methods for Chemical Analysis of Water and
Wastes. EPA-600/4-79-020.
U.S. Environmental Protection Agency. 1981. Methods for Organic Chemical Analysis of
Water and Wastes by GC, HPLC and GC/MS. Environmental Monitoring Support Laboratory,
Cincinnati, Ohio.
U.S. Environmental Protection Agency. 1982. Handbook for Sampling and Sample
Preservation of Water and Wastewater. EPA-600/4-82-029.
Wood, L.B., and Stanbridge, H.H. 1968. "Automatic Samplers," Water Pollution Control, 67(5):
495-520. '
5-26
-------
Chapter Five
Sampling
PERMITTEE SAMPLING INSPECTION CHECKLIST
A. PERMITTEE SAMPLING EVALUATION
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1. Samples taken at sites specified in permit.
2. Locations adequate for representative samples.
3. Flow proportioned samples obtained when required by permit.
4. Sampling and analysis completed on parameters specified by
permit.
5. Sampling and analysis done in frequency specified by permit.
6. Permittee uses method of sample collection required by permit.
Required
method:
If not, method being used is: ( ) Grab ( ) Manual composite
( ) Automatic Composite
7. Sample collection procedures adequate:
a. Samples refrigerated during compositing.
b. Proper preservation techniques used.
c. Containers and sample holding times before analyses.
conform to 40 CFR Part 136.3.
d. Samples analyzed in timeframe needed (same day).
8. Monitoring and analyses performed more often than required by
permit; if so, results reported in permittee's self-monitoring report.
9. Samples contain chlorine.
10. Contract laboratory used for sample analysis.
11. POTW collects samples from industrial users in pretreatment
program.
B. SAMPLING-INSPECTION PROCEDURES AND OBSERVATIONS
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1. Grab samples obtained.
2. Composite sample obtained.
Compositing Frequency:
Preservation:
3. Sample refrigerated during compositing.
4. Flow proportioned sample obtained.
5. Sample obtained from facility sampling device.
6. Sample representative of volume and nature of discharge.
7. Sample split with permittee.
8. Chain-of-custody procedures employed.
9. Samples collected in accordance with permit.
10. Excessive foam, grease, floating solids observed at the outfall.
5-27
-------
Chapter Five Sampling
NOTES
5-28
-------
6. FLOW MEASUREMENT
Contents Page
A. Evaluation of Permittee's Flow Measurement
Objectives and Requirements 6-1
Evaluation of Facility-Installed Flow Devices and Data 6-1
Evaluation of Permittee Data Handling and Reporting 6-3
Evaluation of Permittee Quality Control 6-4
B. Flow Measurement Compliance
Objectives 6-5
Flow Measurement System Evaluation 6-5
Primary Device Inspection Procedures 6-6
Secondary Device Inspection Procedures 6-9
C. References and Flow Measurement Inspection Checklist
References 6-13
Flow Measurement Inspection Checklist 6-15
Associated Appendices
G Further Information on Flow Management Devices
6-i
-------
Chapter Six Contents
• *« Mrvrcc ***
NOTES
6-ii
-------
6. FLOW MEASUREMENT
A. Evaluation of Permittee's Flow
Measurement
Objectives and Requirements
To comply with the permit requirements established under the National Pollutant Discharge
Elimination System (NPDES), the permittee must accurately determine the quantity of
wastewater being discharged. Therefore, discharge flow measurement is an integral part
of the NPDES program and the accuracy of the measurement must be evaluated by the
inspector.
In addition to providing usable information for enforcement purposes, flow measurement
serves to:
• Provide data for pollutant mass loading calculations
• Provide operating and performance data on the wastewater treatment plant
• Compute treatment costs, based on wastewater volume
• Obtain data for long-term planning of plant capacity, versus capacity used.
A Flow Measurement Inspection Checklist for the inspector's use appears at the end of this
chapter.
Evaluation of Facility-Installed Flow Devices and Data
Two types of wastewater flow can be encountered: closed channel flow and open channel
flow. Closed channel flow occurs under pressure in a liquid-full conduit (usually a pipe).
Flow in closed channels is usually measured by a metering device inserted into the conduit.
Examples of closed channel flow measuring devices are the Venturi meter, the pitot tube,
the paddle wheel, and the electromagnetic flowmeter. In practice, closed channel flow is
normally encountered between treatment units in a wastewater treatment plant, where
liquids and/or sludges are pumped under pressure.
Open channel flow occurs in conduits that are not liquid-full. Partially full pipes, not under
pressure, are classified as open channels. Open channel flow is the most prevalent type of
flow at NPDES-regulated discharge points.
Open channel flow is measured using primary and secondary devices. Primary devices are
standard hydraulic structures, such as flumes and weirs, that are inserted in the open
channel. Accurate flow measurements can be obtained merely by measuring the depth of
liquid (head) at the specific point in the primary device. In a weir application, for example,
the flow rate is a function of the head of liquid above the weir crest.
6-1
-------
Chapter Six Flow Measurement
Secondary devices are used in conjunction with primary devices to automate the flow
measuring process. Typically, secondary devices measure the liquid depth in the primary
device and convert the depth measurement to a corresponding flow, using established
mathematical relationships. Examples of secondary devices are floats, ultrasonic
transducers, and bubblers. The output of the secondary device is generally transmitted to
a recorder and/or totalizer to provide instantaneous and historical flow data to the operator.
Outputs may also be transmitted to sampling systems to facilitate flow proportioning.
Further information on flow measurement devices is included in Appendix G.
The permittee must obtain accurate wastewater flow data to calculate mass loading
(quantity) from measured concentrations of pollutants discharged as required by many
NPDES permits. The permittee must produce data that meet requirements in terms of
precision and accuracy. Precision refers to data reproducibility or the ability to obtain
consistent data from repeated measurements of the same quantity. Accuracy refers to the
agreement between the amount of a component measured by the test and the amount
actually present.
The accuracy of flow measurement (including both primary and secondary devices) varies
widely with the device, its location, environmental conditions, and other factors such as
maintenance and calibration. Faulty fabrication, construction, and installation of primary
devices are common sources of errors. Improper calibration, misreading, and variation in
the speed of totalizer drive motors are major errors related to secondary devices. When
evaluating facility installed devices, the inspector should do the following:
• Verify that the primary and secondary devices have been installed according to
manufacturer's instructions and other applicable plans and specifications.
• Inspect the primary device for evidence of corrosion, scale formation, or solids
accumulation that may bias the flow measurement.
• Verify that weirs are level, plumb, and perpendicular to the flow direction.
• Verify that flumes are level, the throat walls are plumb, and the throat width is the
standard size intended.
• Inspect historical records (strip charts, logs, etc.) for evidence of continuous flow
measurements. Compare periods of missing data with maintenance logs for
explanations of measuring system problems.
• Observe the flow patterns near the primary device for excessive turbulence or
velocity. The flow lines should be straight.
• Ensure that the flow measurement system or technique being used measures the
entire wastewater discharge as required by the NPDES permit. A careful inspection
should be conducted to determine whether there are any wastewater diversions,
return lines, or bypasses around the system. Make sure the system meets the
permit requirement, such as instantaneous or continuous, daily, or other time
interval. Anomalies should be noted in the inspection report.
6-2
-------
Chapter Six Flow Measurement
• Verify that the site chosen for flow measurement is appropriate and is in
accordance with permit requirements.
• Verify that the site chosen for flow measurement is suitable for type of discharge,
flow range, suspended solids concentration, and other relevant factors.
• Verify that closed channel flow measuring devices are placed where the pipe is
always full.
• Verify that tables, curves, and formulas are appropriate and are used correctly to
calculate flow rates.
• Review and evaluate calibration and maintenance programs for the discharger's flow
measurement system. The permit normally requires that calibration be checked
regularly by the permittee. The calibration of flow measurement systems must be
checked often enough to ensure their accuracy. Flow measurement systems should
be calibrated by an independent source at least once a year. Lack of such a
program is considered unacceptable for NPDES compliance purposes.
• Verify that primary and secondary devices are adequate for normal flow as well as
maximum expected flow. Note whether the flow measurement system can measure
the expected range of flow.
• Collect accurate flow data during inspection to validate self monitoring data
collected by the permittee.
Evaluation of Permittee Data Handling and Reporting
The permittee or facility must keep flow measurement records for a minimum period of
three years as the permit requires. Many flow measuring devices produce a continuous
flowchart for plant records. Flow records should contain date, flow, time of reading, and
operator's name, if applicable. Maintenance, inspection dates, and calibration data should
also be recorded.
The inspector should review the permittee's records and note the presence or absence of
data such as:
• Frequency of routine operational inspections
• Frequency of maintenance inspections
• Frequency of flowmeter calibration (should be as specified in permit, generally at
least once per year)
• Irregularity or uniformity of flow.
6-3
-------
Chapter Six Flow Measurement
Evaluation of Permittee Quality Control
The following quality control issues should be evaluated carefully during a compliance
inspection:
Proper operation and maintenance of equipment
Accurate records
Sufficient inventory of spare parts
Valid flow measurement techniques
Precise flow data
Adequate frequency of calibration checks.
Precision can be evaluated at float driven devices when flows are stable. The float is
pushed gently downward, held for 30 seconds, then allowed to return normally. The
recorded flow rate should be the same before and after the float was moved. Accuracy
can be evaluated by measuring the instantaneous flow rate at the primary device used at
the facility and comparing the value against the value on the meter, graph, integrator, or
company record. The difference between two stable totalizer readings (flow is steady for
10 minutes or more) should not exceed ±10 percent of the instantaneous flow measured
at the primary device.
Accuracy can also be evaluated by installing a second flow measurement system,
sometimes referred to as a reference system. Agreement in measured flow rates between
the two systems should be within ± 10 percent of the reference rate if all conditions are as
recommended for the systems.
6-4
-------
6. FLOW MEASUREMENT
B. Flow Measurement Compliance
Objectives
The current compliance strategy depends heavily on the permittee's submittal of self-
monitoring data. The flow discharge measured during the NPDES compliance inspection
should verify the flow measurement data collected by the permittee, support any
enforcement action that may be necessary, and provide a basis for reissuing or revising the
NPDES permit.
Flow Measurement System Evaluation
The responsibility of the inspector includes collecting accurate flow data during the
inspection and validating data collected during the permittee's self-monitoring.
The NPDES inspector must check both the permittee's flow data and the flow
measurement system to verify the permittee's compliance with NPDES permit
requirements. When evaluating a flow measurement system, the inspector should consider
and record findings on the following:
• Whether the system measures the entire discharge flow.
• The system's accuracy and good working order. This will include a thorough
physical inspection of the system and comparison of system readings to actual flow
or those obtained with calibrated portable instruments.
• The need for new system equipment.
• The existence or absence of a routine calibration and maintenance program for flow
measurement equipment.
If the permittee's flow measurement system is accurate within ±10 percent, the inspector
is encouraged to use the installed system. If the flow sensor or recorder is found to be
inaccurate, the inspector should determine whether the equipment can be corrected in time
for use during the inspection. If the equipment cannot be repaired in a timely manner, the
portable flow sensor and recorder used to assess the accuracy of the permittee's system
should be used for the duration of the inspection. If nonstandard primary flow devices are
being used, the permittee should supply data on the accuracy and precision of the method
being employed.
For flow measurement in pipelines, the inspector may use a portable flowmeter. The
inspector should select a flowmeter with an operating range wide enough to cover the
6-5
-------
Chapter Six Flow Measurement
anticipated flow to be measured. The selected flowmeter should be tested and calibrated
before use. The inspector should select the site for flow measurement according to permit
requirements and install the selected flowmeter according to the manufacturer's
specifications. The inspector should use the proper tables, charts, and formulas as
specified by the manufacturer to calculate flow rates.
Four basic steps are involved in evaluating the permittee's flow measurement system:
• Physical inspection of the primary device
• Physical inspection of the secondary device and ancillary equipment
• Flow measurement using the primary/secondary device combination of the permittee
• Certification of the system using a calibrated, portable instrument.
In the following sections, procedures are presented for inspecting the more common types
of primary and secondary devices, for measuring flow using common permanent and
portable systems, and for evaluating flow data. It must be emphasized that the number of
primary/secondary device permutations is limitless; therefore, it is not feasible to provide
procedures for all systems. When systems other than those discussed here are
encountered, the inspector is strongly encouraged to consult the manufacturers for advice
before preparing a written inspection procedure.
Primary Device Inspection Procedures
The two most common open channel primary devices are sharp-crested weirs and Parshall
flumes. Common sources of error when using them include the following:
• Faulty fabrication—weirs may be too narrow or not "sharp" enough. Flume
surfaces may be rough, critical dimensions may exceed tolerances, or throat walls
may not be vertical.
• Improper installation—weirs and flumes may be installed too near pipe elbows,
valves, or other sources of turbulence. The devices may be out of level or plumb.
• Sizing errors—the primary device's recommended applications may not include the
actual flow range.
• Poor maintenance—primary devices corrode and deteriorate. Debris and solids may
accumulate in them.
Specific inspection procedures for the sharp crested weir, the Parshall flume, and the
Palmer-Bowlus flume devices follow.
6-6
-------
Chapter Six Flow Measurement
Sharp-Crested Weir Inspection Procedures
• Inspect the upstream approach to the weir.
- Verify that the weir is perpendicular to the flow direction.
- Verify that the approach is a straight section of conduit with a length at least 20
times the maximum expected head of liquid above the weir crest.
- Observe the flow pattern in the approach channel. The flow should occur in
smooth stream lines without velocity gradients and turbulence.
- Check the approach, particularly in the vicinity of the weir, for accumulated
solids, debris, or oil and grease. The approach must have no accumulated
matter.
• Inspect the sharp-crested weir
- Verify that the crest of the weir is level across the entire conduit traverse.
- Measure the width of the weir crest. The edge of the weir crest should be no
more than 1 /8-inch thick.
- Make certain the weir crest corresponds to zero gauge elevation (zero output on
the secondary device).
- Measure the angle formed by the top of the crest and the upstream face of the
weir. This angle must be 90 degrees.
- Measure the chamfer on the downstream side of the crest. The chamfer should
be approximately 45 degrees.
- Visually survey the weir-bulkhead connection for evidence of leaks or cracks
which permit bypass.
- Measure the height of the weir crests above the channel floor. The height
should be at least twice the maximum expected head (2H) of liquid above the
crest.
- Measure the width of the end contraction. The width should be at least twice
the maximum expected head (2H) of the liquid above the crest.
- Inspect the weir for evidence of corrosion, scale formation, or clinging matter.
The weir must be clean and smooth.
- Observe flow patterns on the downstream side of the weir. Check for the
existence of an air gap (ventilation) immediately adjacent to the downstream face
of the weir. Ventilation is necessary to prevent a vacuum that can induce errors
6-7
-------
Chapter Six Flow Measurement
in head measurements. Also ensure that the crest is higher than the maximum
downstream level of water in the conduit.
- Verify that the nappe is not submerged and that it springs free of the weir plate.
- If the weir contains a V-notch, measure the apex angle. The apex should range
from 22.5 degrees to 90 degrees. Verify that the head is between 0.2 and 2.0
feet. The weir should not be operated with a head of less than 0.2 feet since
the nappe may not spring clear of the crest.
King's Handbook of Hydraulics, 1963, frequently referenced throughout this chapter,
provides a detailed discussion on weirs.
Parshall Flume Inspection Procedures
• Inspect the flume approach.
- The flow pattern should be smooth with straight stream lines, be free of
turbulence, and have a uniform velocity across the channel.
- The upstream channel should be free of accumulated matter.
• Inspect the flume.
- The flume should be located in a straight section of the conduit.
- Flow at the entrance should be free of "white" water.
- The flume should be level in the transverse and translational directions.
- Measure the dimensions of the flume. Dimensions are strictly prescribed as a
function of throat width (see Figure G-5 in Appendix G for critical dimensions).
- Measure the head of liquid in the flume and compare with the acceptable ranges
in Table G-4.
• Inspect the flume discharge
- Verify that the head of water in the discharge is not restricting flow through the
flume. The existence of a "standard wave" is good evidence of free flow and
verifies that there is no submergence present.
- Verify whether submergence occurs at near maximum flow (e.g., look for water
marks on the wall).
6-8
-------
Chapter Six Flow Measurement
Palmer-Bowlus Flume Inspection Procedures
• Inspect the flume approach as outlined above (these flumes are seldom used for
effluent flow measurement).
• Inspect the flume
- The flume should be located in a straight section of the conduit.
- Flow at the entrance should be free of "white" water.
- Observe the flow in the flume. The profile should approximate that depicted in
Figure G-8.
- The flume should be level in the transverse direction and should not exceed the
translational slope in Table G-6.
- Measure the head of water in the flume. Head should be within the ranges
specified in Table G-6.
• Inspect the flume discharge
- Verify that free flow exists. Look for the characteristic "standing wave" in the
divergent section of the flume.
Venturi Meter Inspection Procedures
• Verify that the Venturi meter is installed according to manufacturer's instructions.
• Verify that the Venturi meter is installed downstream from a straight and uniform
section of pipe, at least 5 to 20 diameters, depending on the ratio of pipe to throat
diameter and whether straightening vanes are installed upstream. (Installation of
straightening vanes upstream will reduce the upstream piping requirements.)
• Verify that the pressure measuring taps are not plugged.
• Calibrate the Venturi meter in place by either the volumetric method or the
comparative dye dilution method to check the manufacturer's calibration curve or to
develop a new calibration curve.
Secondary Device Inspection Procedures
The following are common sources of error in the use of secondary devices:
• Improper location—gauge is located in the wrong position relative to the primary
device.
6-9
-------
Chapter Six Flow Measurement
• Inadequate maintenance—gauge is not serviced regularly.
• Incorrect zero setting—zero setting of gauge is not the zero point of the primary
device.
• Operator error—human error exists in the reading.
Specific inspection procedures follow.
Flow Measurement in Weir Applications
• Determine that the head measurement device is positioned 3 to 4 head lengths
upstream of a weir.
• Verify that the zero or other point of the gauge is equal to that of the primary
device.
The inspector should use an independent method of measuring head, such as with a
yardstick or carpenter's rule (be sure to measure at least 4 HmB( upstream and convert to
nearest hundredth of a foot). To determine flow rate, use the appropriate head discharge
relationship formula (see Table G-1).
Flow Measurement in Parshall Flume Applications
Flow Measurement—Free-Flow Conditions.
• Determine upstream head (H.) using staff gauge.
- Verify that staff gauge is set to zero head. A yardstick or carpenter's rule can be
used.
- Verify that staff gauge is at proper location (two-thirds the length of the
converging section back from the beginning of the throat).
- Read to nearest division the gauge division at which liquid surface intersects
gauge.
- Read H. in feet from staff gauge.
• To determine flow rate, use Figure G-6 in the unit desired, use tables published in
flow measurement standard references, or calculate using the coefficients in
Table G-5.
Flow Measurement—Submerged-Flow Condition. Generally, it is difficult to make field
measurements with submerged-flow conditions. In cases when measurements can be
obtained (using a staff or float gauge), the procedures listed below should be followed:
6-10
-------
Chapter Six Flow Measurement
• Determine upstream head using staff or float gauge.
- Read to nearest division and, at the same time as for Hb, the gauge division at
which liquid surface intersects gauge.
- Calculate H. from gauge reading.
• Determine downstream head (Hb) using staff or float gauge.
- Hb refers to a measurement at the crest.
- Read to nearest division, and at the same time as for H., the gauge division at
which liquid surface intersects gauge.
- Calculate Hb from staff reading.
• Determine flow rate.
- Calculate percent submergence:
- Consult Table G-6.
- When a correction factor is obtained, use H. and find free-flow from Figure G-6.
- Multiply this free-flow value by the correction factor to obtain the submerged
flow.
The inspector may use an independent method of measuring head, such as a yardstick or
carpenter's rule at the proper head measurement point. Because of the sloping water
surface in the converging section of a flume, it is essential that the proper head
measurement point be used.
Flow Measurement in Palmer-Bowlus Flume Applications
• Obtain head measurements as in the Parshall Flume application, using the secondary
device. The head is the height of water above the step. The total depth upstream
of the step is not the head.
• Refer to manufacturer-supplied discharge tables to convert head measurements to
flow data. Palmer-Bowlus flumes, unlike Parshall flumes, are not constructed to
standard dimensional standards. The inspector must not use discharge tables
supplied by other manufacturers.
6-11
-------
Chapter Six Flow Measurement
Verification
Most flow measurement errors result from inadequate calibration of the flow, totalizer, and
recorder. If the inspector has determined that the primary device has been installed
properly, verification of the permittee's system is relatively simple. The flow determined
from the inspector's independent measurement is compared to the flow of the permittee's
totalizer or recorder. The inspector's flow measurements should be within 10 percent of
the permittee's measurements to certify accurate flow measurement. Optimally, flow
comparisons should be made at various flow rates to check system accuracy.
When the permit requires that the daily average flow be measured by a totalizing meter,
the inspector should verify that the totalizer is accurate, i.e., properly calibrated. This can
be done during a period of steady flow by reading the totalizer and at the same time
starting a stopwatch. The stopwatch should be started just as a new digit starts to appear
on the totalizer. After 10 to 30 minutes, the totalizer should be read again; just as a new
digit begins to appear, the stop watch is read. By subtraction of the two totalizer readings,
the total flow over the measured time period can be obtained. The flow rate in gallons per
minute can be calculated by using the time from the stop watch. This flow rate should be
compared to the flow determined by actual measurement of the head made at the primary
device at the time interval. The calibration of the totalizer should be considered
satisfactory if the two flows are within 10 percent of each other, when the actual
measured flow is used as the known value, or divisor, in the percent calculation.
6-12
-------
6. FLOW MEASUREMENT
C. References and Flow Measurement
Inspection Checklist
References
American Petroleum Institute. 1969. Manual on Disposal of Refinery Wastes, Chapter 4.
Associated Water and Air Resource Engineers, Inc. 1973. Handbook for Industrial
Wastewater Monitoring. USEPA, Technology Transfer.
Blasso, L. 1975. "Flow Measurement Under Any Conditions," Instruments and Control
Systems, 48(2): 45-50.
Bos, M.G. 1976. Discharge Measurement Structures, Working Group on Small Hydraulic
Structures International Institute for Land Reclamation and Improvement, Wageningen, The
Netherlands.
Eli, R., and H. Pederson. 1979. Calibration of a 90° V-Notch Weir Using Parameters
Other than Upstream Head. EPA-61809A-2B.
ISCO. 1985. Open Channel Flow Measurement Handbook, Lincoln, Nebraska. (Contains
tables of various flow measurement devices.)
King, H.W., and E.F. Brater. 1963. Handbook of Hydraulics. 5th ed. New York:
McGraw-Hill Book Co. (contains tables of various flow measurement devices.)
Mauis, FT. 1949. "How to Calculate Flow Over Submerged Thin-Plate Weirs." Eng.
News-Record, p. 65.
Metcalf & Eddy, Inc. 1972. Wastewater Engineering. New York: McGraw Hill Book Co.
Robinson, A.R. 1965. Simplified Flow Corrections for Parshall Flumes Under Submerged
Conditions, Civil Engineering, ASCE.
Shelley, P.E., and G.A. Kirkpatrick. 1975. Sewer Flow Measurement; A State of the Art
Assessment, U.S. Environmental Protection Agency, EPA-600/2-75-027.
Simon, A. 1976. Practical Hydraulics. New York: John Wiley & Sons.
Smoot, G.F. 1974. A Review of Velocity-Measuring Devices. U.S. Department of the
Interior (USDI), United States Geological Survey (USGS). Open File Report, Reston,
Virginia.
6-13
-------
Chapter Six Flow Measurement
Stevens. Water Resources Data Book, Beaverton, Oregon. (Contains tables of various
flow measurement devices.)
Thorsen, T., and R. Oden. 1975. "How to Measure Industrial Wastewater Flow,"
Chemical Engineering, 82(4): 95-100.
U.S. Department of Commerce, National Bureau of Standards. 1975. A Guide to Methods
and Standards for the Measurement of Water Flow.
U.S. Department of the Interior (USDI), Bureau of Reclamation. 1967. Water
Measurement Manual, 2nd Ed. (Contains tables of various flow measurement devices.)
6-14
-------
Chapter Six
Flow Measurement
FLOW MEASUREMENT INSPECTION CHECKLIST
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
A. GENERAL
1 . a. Primary flow measuring device properly installed and
maintained.
b. Flow measured at each outfall? Number of
outfalls?
c. Is there a straight length of pipe or channel before and after
the flowmeter of at least 5 to 20 diameters?
d. If a magnetic flowmeter is used, are there sources of
electric noise in the near vicinity?
e. Is the magnetic flowmeter properly grounded?
f . Is the full pipe requirement met?
2. a. Flow records properly kept.
b. All charts maintained in a file.
c. All calibration data entered into a log book.
3. Actual discharged flow measured.
4. Effluent flow measured after all return lines.
5. Secondary instruments (totalizers, recorders, etc.) properly
operated and maintained.
6. Spare parts stocked.
7. Effluent loadings calculated using effluent flow.
B. FLUMES
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
Flow entering flume reasonably well-distributed across the
channel and free of turbulence, boils, or other disturbances.
Cross-sectional velocities at entrance relatively uniform
Flume clean and free of debris and deposits.
All dimensions of flume accurate and level.
Side walls of flume vertical and smooth.
Sides of flume throat vertical and parallel.
Flume head being measured at proper location.
Measurement of flume head zeroed to flume crest.
Flume properly sized to measure range of existing flow.
Flume operating under free-flow conditions over existing range o
flows.
Flume submerged under certain flow conditions.
Flume operation invariably free-flow. |
6-15
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Chapter Six
Flow Measurement
FLOW MEASUREMENT INSPECTION CHECKLIST
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
(Continued)
C. WEIRS
What type of weir is being used?
Weir exactly level.
Weir plate plumb and its top and edges sharp and clean.
Downstream edge of weir is chamfered at 45°.
Free access for air below the nappe of the weir.
Upstream channel of weir straight for at least four times the
depth of water level and free from disturbances.
Distance from sides of weir to side of channel at least 2H.
Area of approach channel at least (8 x nappe area) for upstream
distance of 15H.
If not, is velocity of approach too high?
Head measurements properly made by facility personnel.
Leakage does not occur around weir.
Proper flow tables used by facility personnel.
D. OTHER FLOW DEVICES
1.
2.
3.
Type of flowmeter used:
What are the most common problems that the operator has had
with the flowmeter?
Measured wastewater flow: mgd; Recorded flow:
; Error %
Yes
No
N/A
Yes
Yes
Yes
No
No
No
N/A
N/A
N/A
E. CALIBRATION AND MAINTENANCE
1.
2.
3.
4.
5.
6.
Flow totalizer properly calibrated.
Frequency of routine inspection by proper operator:
/day.
Frequency of maintenance inspections by plant personnel:
/year.
Flowmeter calibration records kept. Frequency of
calibration: /month.
Flow measurement equipment adequate to handle
ranges of flow rates.
Calibration frequency adequate.
flowmeter
expected
6-16
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7. LABORATORY PROCEDURES AND
QUALITY ASSURANCE
Contents Page
A. Objectives and Requirements
B. Sample Handling Procedures
Evaluation of Permittee Sample Handling Procedures 7-3
C. Laboratory Analyses Techniques Evaluation
Evaluation of Permittee Laboratory Analytical Procedures 7-5
Evaluation of Permittee Laboratory Facilities and Equipment 7-6
D. Quality Assurance and Quality Control
Evaluation of the Precision and Accuracy of the Permittee Laboratory 7-9
Evaluation of Permittee Data Handling and Reporting 7-10
Evaluation of Permittee Laboratory Personnel 7-11
Evaluation of Contract Laboratories 7-12
Overview of the Discharge Monitoring Report Quality Assurance Program and
How It Relates to the Inspection Program 7-12
E. References and Laboratory Quality Assurance Checklist
References 7-15
Laboratory Quality Assurance Checklist 7-16
7-i
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Chapter Seven
Contents
NOTES ***
7-ii
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7. LABORATORY PROCEDURES AND
QUALITY ASSURANCE
A. Objectives and Requirements
The analytical laboratory provides both qualitative and quantitative information for determining
the extent of permittee compliance. To be valuable or useful, the data must be representative
and accurately describe the characteristics and concentrations of constituents in the samples
submitted to the laboratory. The objectives of laboratory Quality Assurance (QA) are to
monitor and document the accuracy and precision of the results reported and to meet
reliability requirements.
QA refers to a total program for ensuring the reliability of data by utilizing administrative and
technical procedures and policies regarding personnel, resources, and facilities. QA is
required for all functions bearing on environmental measurements and includes activities such
as project/study definition; sample collection and tracking; laboratory analysis; data validation,
analysis, reduction, and reporting; documentation; and data storage systems. Thus, the QA
program is designed to evaluate and maintain the desired quality of data. Examples of QA
include the use of spiked, duplicate, and performance evaluation samples. Quality Control
(QC), a function of QA, is the routine application of procedures for controlling the accuracy
and precision of the measurement process and includes the proper calibration of instruments
and the use of the appropriate analytical procedures.
Laboratory QA is required by 40 Code of Federal Regulations (CFR) Section 122.41 (e)
(conditions applicable to all permits), which states that adequate laboratory and process
controls, including appropriate QA procedures, must be provided. Each permittee's laboratory
should have a QA/QC program. The QA program should be documented in a written QA/QC
manual distributed to all personnel responsible for sample analyses. This manual should
identify clearly the individuals involved in the QA program and their responsibilities and should
document the laboratory's standard operating procedures that meet user requirements in
terms of specificity, completeness, precision, accuracy, representativeness, and comparability.
Approximately 10 to 20 percent of each laboratory's resources should be devoted to its
QA/QC program.
Guidance in this chapter is broad based and may not be applicable to every laboratory. A
Laboratory Quality Assurance Checklist for the inspector's use is included at the end of this
chapter. For detailed information concerning laboratory QA, refer to Environmental Protection
Agency's (EPA's) Handbook for Analytical Quality Control in Water and Wastewater
Laboratories (USEPA 1979a). Further information is also available in the U.S. Environmental
Protection Agency's (EPA's) NPDES Compliance Monitoring Inspector Training Laboratory
Analysis Module (April 1990).
7-1
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Chapter Seven Laboratory Procedures and Quality Assurance
*** NOTES ***
7-2
-------
7. LABORATORY PROCEDURES AND
QUALITY ASSURANCE
B. Sample Handling Procedures
Evaluation of Permittee Sample Handling Procedures
Proper sample handling procedures are necessary in the laboratory from the sample's receipt
until it is discarded. Sample handling procedures for small permittees may differ from
procedures for larger permittees because staff organizational structures and treatment facility
designs vary from one facility to the next. However, proper sample handling procedures
should be standardized, utilized and documented by all permittees to produce evidence that
can be used in an enforcement action. In evaluating laboratory sample handling procedures,
the inspector should verify the following:
• The laboratory has a sample custodian.
• The laboratory area is a secured area and is restricted to authorized personnel only.
• The laboratory has a sample security area that is dry, clean, and isolated; has
sufficient refrigerated space; and can be locked securely.
• Samples are handled by a minimum number of people.
• All incoming samples are received by the custodian, who signs the chain-of-custody
record sheet accompanying the samples and retains the sheet as a permanent record.
• The custodian has ensured that samples are properly stored.
• Only the custodian distributes samples to personnel who are to perform analyses.
• Transfer of samples is always documented.
• Care and custody records for handling samples are accurate and up-to-date.
7-3
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Chapter Seven Laboratory Procedures and Quality Assurance
*** NOTES ***
7-4
-------
7. LABORATORY PROCEDURES AND
QUALITY ASSURANCE
C. Laboratory Analyses Techniques
Evaluation
Evaluation of Permittee Laboratory Analytical Procedures
The methods used by the permittee's laboratories or its contract laboratories must be uniform,
thus, eliminating methodology as a variable when data are compared or shared among
laboratories. Procedures used by the permittee's laboratory must be selected by consulting
40 CFR Part 136 or EPA for approval of alternative methods. Alternative test procedures may
be implemented only if the required written EPA approval has been obtained, as specified by
40 OFF! Parts 136.4 and 136.5, and promulgated under Public Law (PL) 92-500.
Many standardized test procedures that have been promulgated under 40 CFR 136 are
covered in Methods for Chemical Analysis of Water and Wastes (USEPA 1979b). Revisions
and new additions to this publication are-made whenever new analytical techniques or
instruments are developed. These are considered accepted after final publication in the
Federal Register. Other acceptable methods are specified in the latest accepted edition of
Standard Methods for the Examination of Water and Wastewater [American Public Health
Association (APHA), American Water Works Association (AWWA), and Water Environment
Federation (WEF)]. (The most current 40 CFR Part 136 may supersede any method or
technique cited in this manual.)
In evaluating laboratory analytical procedures, the inspector should verify the following:
• Analytical methods specified in 40 CFR Part 136 are followed and any deviations
allowed by 40 CFR Part 136 are properly performed.
• The QC system used conforms to the system specified in the permit or to that detailed
in published Standard Methods (APHA, AWWA, and WEF).
• A QC record is maintained on reagent preparation, instrument calibration and
maintenance, and purchase of supplies.
• QC checks are made on materials, supplies, equipment, instrument calibration and
maintenance, facilities, analyses, and standard solutions.
7-5
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Chapter Seven Laboratory Procedures and Quality Assurance
Steps and procedures stated in the method specified in 40 CFR Part 136 are followed.
Documentation of any EPA-approved deviation from specified test procedures is
available.
Evaluation of Permittee Laboratory Facilities and Equipment
To verify that the proper analytical procedures are being followed, the inspector should have
the responsible analyst describe each of the procedures. The inspector should be alert to any
deviation from the specified analytical method. Any questions regarding the proper
procedures can be resolved by referring to the cited methodology. Even simple analyses can
yield invalid results if the methodology cited in 40 CFR Part 136 is not exactly followed.
Laboratory Services
The availability of laboratory services affects data reliability. The inspector should verify that
the following items are provided:
• An adequate supply of laboratory pure water, free from chemical interferences and
other undesirable contaminants. Water quality should be checked routinely and
documented.
• Adequate bench, instrumentation, storage, and recordkeeping space.
• Adequate humidity and temperature control.
• Adequate lighting and ventilation.
• Dry, uncontaminated, compressed air when required.
• Efficient fume hood systems.
• Necessary equipment such as hot plate, incubator, water bath, refrigerator for samples,
pH meter, thermometer, and balance.
• Electrical power for routine laboratory use and, if appropriate, voltage-regulated
sources for delicate electronic instruments.
• Emergency equipment, fire extinguisher, eye wash station, shower, first aid kit, gloves,
and goggles.
• Vibration-free area for accurate weighings.
The inspector should also check that proper safety equipment (gloves, goggles, and fume
hoods) are being used where necessary. The laboratory should be equipped with a fire
7-6
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Chapter Seven Laboratory Procedures and Quality Assurance
extinguisher, eye wash station, shower, and first aid kit. Any problems noted should be
documented and referred to the proper authority [e.g., Occupational Safety and Health
Administration (OSHA)].
Instruments and Equipment
Instrumentation is extremely important in the analytical laboratory. To a certain extent,
analytical instrumentation is always developmental; manufacturers are continually redesigning
and upgrading their products, striving for miniaturization, enhanced durability and sensitivity,
and improved automation. In evaluating laboratory instruments and equipment, the inspector
should verify the following:
• Standard and specific procedures for cleaning glassware and containers are followed.
Chapter 2 of EPA's NPDES Compliance Monitoring Inspector Training Laboratory
Analysis Module (April 1990) contains detailed information on glassware cleaning.
• Written requirements (e.g., instruction manuals) for daily operation of instruments and
equipment are provided and followed.
• Standards and appropriate blanks are available to perform standard calibration
procedures. Standard concentrations that closely bracket actual sample
concentrations should be used.
• Written troubleshooting procedures are available to identify common equipment
malfunctions.
• Written schedules for replacement, cleaning, checking, and/or adjustment by service
personnel are available and followed.
• Documentation is maintained on equipment maintenance and service checks.
Commonly used analytical instruments include analytical balances, pH meters, dissolved
oxygen meters, conductivity meters, turbidimeters, spectrophotometers, atomic absorption
spectrophotometers, organic carbon analyzers, selective ion analyzers, gas-liquid
chromatographs, titrimetric analyses, and temperature controls. Detailed discussions on these
instruments are included in Chapter 2 of EPA's NPDES Compliance Monitoring Inspector
Training Laboratory Analysis Module. (April 1990).
Maintenance of laboratory facilities and equipment is an important factor in laboratory QA.
Supplies
Chemical reagents, solvents, and gases are available in many grades of purity, ranging from
technical grade to various ultrapure grades. The purity of the materials required in analytical
chemistry varies with the type of analysis. The parameter being measured, the analytical
method, and the sensitivity and specificity of the detection system determine the purity of the
7-7
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Chapter Seven Laboratory Procedures and Quality Assurance
reagents required. Reagents of lesser purity than that specified by the method should not be
used. In evaluating laboratory supplies, the inspector should verify that:
• The required reagent purity for the specific analytical method is used
• Standard reagents and solvents are stored according to the manufacturer's directions
• Working standards are checked frequently to determine changes in concentration or
composition
• Concentrations of stock solutions are verified before being used to prepare new
working standards
• Laboratory supplies with limited shelf life are dated upon receipt and shelf-life
recommendations, including the discard date on the container and the storage
requirements, are observed
• Reagents are prepared and standardized against reliable primary standards
• Standards and reagents are labeled properly including the date of preparation and
analyst's identification.
• Standards and reagents are stored in appropriate containers and under required
conditions.
• Purchased solutions contain the chemicals specified by the method being used and
are checked for accuracy.
• Clean containers of suitable composition with tight-fitting stoppers or caps should be
used for storage.
• Reagents are discarded when signs of discoloration, formation of precipitates, or
significant changes in concentrations are observed.
• Stock solutions and standards should be prepared using volumetric glassware.
7-8
-------
7. LABORATORY PROCEDURES AND
QUALITY ASSURANCE
D. Quality Assurance and Quality
Control
Evaluation of the Precision and Accuracy of the Permittee Laboratory
The purpose of laboratory control procedures is to ensure high-quality analyses by the use of
control samples, control charts, reference materials, and instrument calibration. Controls must
be initiated and maintained throughout the analysis of samples. Specifically, each testing
batch must contain at least one blank, standard, duplicate, and spiked (as applicable) sample
analysis. When a batch contains more than 10 samples, every tenth sample should be
followed by a duplicate and a spike (as applicable).
The precision of laboratory findings refers to the reproducibility or degree of agreement among
replicate measurements of the same quantity. The closer the numerical values of the
measurements come to each other, the more precise are the measurements. In a laboratory
QC program, precision is estimated by the analysis of actual samples in duplicate. These
may represent a range of concentrations and a variety of interfering materials usually
encountered during the analysis. Accuracy refers to the degree of difference between
observed values and known or actual values. The closer the value of the measurement
comes to the actual value, the more accurate the measurement is. The accuracy of a method
can be determined by analyses of samples to which known amounts of reference standards
have been added (spiked samples).
In evaluating the precision of the measurement process, the inspector should verify that:
• Control samples are introduced into the train of actual samples to monitor the
performance of the analytical system.
• Duplicate analyses are performed with each batch of samples to determine precision.
In general, 10 percent of the samples should be duplicated.
• Precision control charts or other statistical techniques for each analytical procedure are
prepared and used. Precision control charts should be developed by collecting data
from a minimum of 15 to 20 duplicate samples (run in controlled conditions) over an
extended period (e.g., 10 to 20 days). Statistical methods include calculation of mean,
standard deviation, and variance to define the range and variability of the data.
7-9
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Chapter Seven Laboratory Procedures and Quality Assurance
• Corrective actions are taken when data fall outside the warning and control limits.
• The out-of-control data or situation and the corrective action taken are fully
documented.
In evaluating accuracy, the inspector should verify that:
• Spiked samples are introduced into the train of actual samples at least 10 percent of
the time to monitor the performance of the analytical system.
• Spiked samples are used to monitor accuracy in each sample batch.
- The amount of additive is appropriate to the detection limit and sample
concentration.
• Accuracy control charts for each analytical procedure are prepared and used.
Accuracy control charts should be developed by collecting data for a minimum of 15 to
20 samples over an extended period of time.
- Accuracy limits are established based on standard deviations whose upper and
lower control limits are established at three times the standard deviation above and
below the central line.
- The upper and lower warning limits are established at twice the standard deviation
above and below the central line. Note: Some parameters have a defined warning
limit required by 40 CFR 136.
- Corrective actions are taken when data fall outside the warning and control limits.
- The out-of-control data or situation and the corrective action taken are fully
documented.
Evaluation of Permittee Data Handling and Reporting
An analytical laboratory must have a system for uniformly recording, processing, and reporting
data. In evaluating permittee data handling and reporting, the inspector should verify that:
• Correct formulas are used to calculate the final results.
• Round-off rules are uniformly applied.
• Significant figures are established for each analysis.
• Provisions are available for cross-checking calculations.
• Control chart approaches and statistical calculations have been determined for the
purposes of QC and reporting.
7-10
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Chapter Seven Laboratory Procedures and Quality Assurance
The laboratory report forms provide complete data documentation and permanent
recording, and they facilitate data processing.
The program for data handling provides data in the form/units required for reporting.
Laboratory records are kept readily available to the regulatory agency for a minimum of
3 years (or longer if requested by EPA or the State).
Laboratory notebooks or pre-printed data forms are bound permanently to provide
good documentation, including the procedures performed and the details of the
analysis, such as the original value recorded, correction factors applied, blanks used,
and the reported data values. The dated notes indicate who performed the tests and
include any abnormalities that occurred during the testing procedure. The notes are
retained as a permanent laboratory record.
Computer data are backed up with duplicate copies.
Proper data handling and reporting procedures are implemented by all contract
laboratories performing sample analyses.
Evaluation of Permittee Laboratory Personnel
Analytical operations in the laboratory vary in complexity. Consequently, work assignments in
the laboratory should be clearly defined. All analysts should be thoroughly instructed in basic
laboratory operations. Those persons performing complex analytical tasks should be qualified
and properly trained. All analysts must follow specified laboratory procedures and be skilled
in using the laboratory equipment and techniques required for the analyses assigned to them.
In evaluating laboratory personnel, the inspector should consider the following factors:
• Adequacy of training
• Skill and diligence in following procedures
• Skill and knowledge in using equipment and analytical methods (particularly for
complex equipment such as gas chromatography)
• Precision and accuracy in performing analytical tasks
• Assignment of clearly defined tasks and responsibilities.
Evaluation of Contract Laboratories
When laboratories are contracted to analyze samples, the inspector may need to ensure that
the laboratory practices at the contracted laboratory are also evaluated. The practices can
also be evaluated by other designated EPA inspectors. If a deficiency is identified at a
contract laboratory, the permittee is responsible for the deficiency and will be notified.
7-11
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Chapter Seven Laboratory Procedures and Quality Assurance
Overview of the Discharge Monitoring Report Quality Assurance Program and How It Relates
to the Inspection Program
The validity of the National Pollutant Discharge Elimination System (NPDES) program
depends on the quality of the self-monitoring program. The Discharge Monitoring Report
Quality Assurance (DMR QA) program is an important tool used to ensure the quality of
NPDES self-monitoring data. The program is designed to evaluate and improve the ability of
laboratories serving NPDES permittees to analyze and report accurate self-monitoring data.
Major permittees under NPDES are sent performance evaluation samples containing
constituents normally found in industrial and municipal wastewaters. They are to analyze
these samples using the analytical methods and laboratory normally employed for their
reporting of NPDES self-monitoring data. Responding permittees subsequently receive a
report showing evaluation of their reported data.
Highlights
• The DMR QA Program has been an excellent means of focusing on and improving the
quality of laboratory results used in developing DMR data. Improvements in the DMR
QA data have been significant.
• This program has helped major permittees identify and correct both analytical and data
handling problems in their laboratories.
• In general, permittees are receptive to the program and recognize its value, including
some who challenged EPA's authority to require participation.
• Regions and States are generally supportive and have made good use of the results of
this program for targeting inspections and directing other follow-up activities. This
ability to concentrate corrective actions on problem permittees results in an increased
efficiency in improving the self-monitoring data of all NPDES permittees.
• The program is one of the least resource-intensive methods for maintaining direct and
regular technical contact with NPDES permittees. It has been recognized as a
cost-effective effort.
• Utilizing computer technology, the following ways of managing and analyzing DMR QA
data were started in FY 1985: compiling tracking summaries, comparing performance
of the major industries, tracking multiple permittees, and regenerating past
performance evaluation reports.
The DMR QA Program and the NPDES inspection programs are interdependent in several
areas. First, in targeting the inspections, the DMR QA evaluations of permittee performance
can be used, since the evaluations identify potential problems in laboratory analysis or data
handling and reporting. This targeting helps to direct limited resources to permittees who
need them most.
7-12
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Chapter Seven Laboratory Procedures and Quality Assurance
The inspections and DMR QA results are tracked, and results are provided to the DMR QA
coordinators at EPA Regional Offices and NPDES States. To track follow-up and complete
statistical evaluations properly, a code is provided in Inspection Report Form 3560-3 to
indicate when an inspection is the result of a DMR QA evaluation. (This is shown with the
Code Q on the inspection form.)
Finally, inspections, particularly the Performance Audit Inspection (PAI), can be used to follow
up the DMR QA. The DMR QA results should be cross-checked with the permit prior to the
onsite visit, and parameters that were failed should be stressed during a laboratory inspection.
7-13
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Chapter Seven Laboratory Procedures and Quality Assurance
*** NOTES ***
7-14
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7. LABORATORY PROCEDURES AND
QUALITY ASSURANCE
E. References and Laboratory Quality
Assurance Checklist
References
American Society for Testing and Materials (ASTM). Annual Book of Standards, Part 31,
Water. ASTM, Philadelphia, PA.
APHA, AWWA, and WEF. Standard Methods for the Examination of Water and Wastewater.
(Use the most current, EPA-approved edition.)
Brown, E., M.W. Skougstad, and M.J. Fishman. 1970. Methods for Collection and Analysis of
Water Samples for Dissolved Minerals and Gases. U.S. Geological Survey Techniques of
Water Resources Inv,, Book 5.
Delfino, J.J. 1977. "Quality Assurance in Water and Wastewater Analysis Laboratories."
Water and Sewage Works, 124(7): 79-84.
U.S. Environmental Protection Agency. 1979a. Handbook for Analytical Quality Control in
Water and Wastewater Laboratories. EPA-600/4-79-019.
U.S. Environmental Protection Agency. 1979b. Methods for Chemical Analysis of Water and
Wastes. EPA-600/4-79-020.
Federal Register, Vol 51. No. 125, June 30, 1986. Guidelines Establishing Test Procedures
for the Analysis of Pollutants Under the Clean Water Act (also see October 26, 1986).
Plumb, R.H., Jr. 1981. "Procedure for Handling and Chemical Analysis of Sediment and Water
Samples." Technical Report EPA/CE-81-1.
United States Geologic Survey (USGS), United States Department of the Interior (USDI),
Open File Report 85-495; 1906 (see 6/30/86 PR for full citation).
U.S. Environmental Protection Agency. April 1990. NPDES Compliance Monitoring Inspector
Training Laboratory Analysis Module.
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Chapter Seven
Laboratory Procedures and Quality Assurance
LABORATORY QUALITY ASSURANCE CHECKLIST
A. GENERAL
| Yes No N/A | 11. Written laboratory QA manual available.
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
Yes
No
N/A
Yes
Yes
Yes
Yes
No
No
No
No
N/A
N/A
N/A
N/A
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
B. LABORATORY PROCEDURES
1. EPA-approved analytical testing procedures used and on-hand.
(written)
2. If alternate analytical procedures used, proper approval obtained.
3. Calibration and maintenance of instruments and equipment
satisfactory.
4. QA procedures used.
5. QC procedures adequate.
6. Duplicate samples analyzed
% of time.
7. Spiked samples used
% of time.
8. Commercial laboratory used.
Name
Address
Contact
Phone
Certification #
C. LABORATORY FACILITIES AND EQUIPMENT
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
Proper grade laboratory pure water available for specific analysis.
Dry, uncontaminated compressed air available.
Fume hood sufficiently ventilated.
Laboratory sufficiently lighted.
Adequate electrical sources available.
Instruments/equipment in good condition.
Written requirements for daily operation of instruments
Standards and appropriate blanks available to perform
procedures.
available.
daily check
Written troubleshooting procedures for instruments available.
Schedule for required maintenance exists.
Proper volumetric glassware used.
Glassware properly cleaned.
Standard reagents and solvents properly stored.
Working standards frequently checked.
Standards discarded after recommended shelf-life has
expired.
Background reagents and solvents run with every series of
samples.
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Chapter Seven
Laboratory Procedures and Quality Assurance
LABORATORY QUALITY ASSURANCE CHECKLIST
Yes
Yes
No
No
N/A
N/A
17.
18.
(Continued)
Written procedures exists for cleanup,
and applications of correction methods
Gas cylinders replaced at 100-200 psi.
hazard response
for reagents and
methods,
solvents.
D. LABORATORY'S PRECISION, ACCURACY, AND CONTROL PROCEDURES
Yes
Yes
Yes
Yes
No
No
No
No
N/A
N/A
N/A
N/A
1. Multiple replicates (blanks, duplicates, spikes, and splits) analyzed
for each type of control check and information recorded.
2. Plotted precision and accuracy control methods used to determine
whether valid, questionable, or invalid data are being generated
from day to day.
3. Control samples introduced into the train of actual samples to
ensure that valid data are being generated.
4. Precision and accuracy of the analyses are sufficient.
E. DATA HANDLING AND REPORTING
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Round-off rules uniformly applied.
Significant figures established for each analysis.
Provision for cross-checking calculation used.
Correct formulas used to calculate final results.
Control chart approach and statistical calculations for QC and
report available and followed.
Report forms developed to provide complete data documentation
and permanent records and to facilitate data processing.
Data reported in proper form and units.
Laboratory records readily available to regulatory agency for
required time of 3 years.
Laboratory notebook or pre-printed data forms bound permanently
to provide good documentation.
Efficient filing system exists, enabling prompt channeling of report
copies.
Yes No N/A
Yes No N/A
Yes No N/A
F. LABORATORY PERSONNEL
1. Enough analysts present to perform the analyses necessary.
2. Analysts have on hand the necessary references for EPA
procedures being used.
3. Analysts trained in procedures performed through formal or informal
training or certification programs.
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Chapter Seven Laboratory Procedures and Quality Assurance
*** NOTES ***
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8. TOXICITY
Contents Page
A. Objectives
B. Requirements of WET Testing
Types of WET Testing 8-3
WET Test Components 8-4
Effluent .8-4
Dilution Water 8-5
Test System 8-6
Test Organisms 8-6
Reference Toxicants 8-7
Recordkeeping and Data Reporting 8-8
C. Analysis of Results
List of Tables
8-1 Recommended Sampling Strategies for Continuous and Intermittent
Discharges for Flow-Through, Static Renewal, and Static Toxicity Tests 8-9
Associated Appendices
H Recommended Effluent Toxicity Test Conditions
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Chapter Eight Contents
NOTES ***
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Chapter Eight Toxicity
8. TOXICITY
A. Objectives
By definition, toxicity is a characteristic of a substance (or group of substances) that causes
adverse effects in organisms. Adverse effects include an increased rate of morbidity (the rate
of occurrence of disease) and mortality (the rate of occurrence of death), as well as those
effects that limit an organism's ability to survive in nature, such as impaired reproductive
ability. Toxicity of a substance is measured by observing the responses of organisms to
increasing concentrations of that substance. One substance is more toxic than another when
it causes the same adverse effects at a lower concentration.
Whole Effluent Toxicity (WET) is a National Pollutant Discharge Elimination System (NPDES)
permit parameter designed to evaluate the toxicity of the entire wastestream and not individual
pollutants. The WET testing may be either performed or evaluated as part of one of five
NPDES inspections:
Compliance Evaluation Inspection (CEI)
Compliance Sampling Inspection (CSI)
Performance Audit Inspection (PAI)
Toxics Sampling Inspection (XSI)
Compliance Biomonitoring Inspection (CBI).
In addition, the toxicity of a municipal treatment plant effluent should be considered as part of
the Pretreatment Compliance Inspection (PCI), especially if the cause of the toxicity has been
investigated and found to be from industrial or commercial dischargers contributing to the
system.
The inspector should understand the permittee's WET testing requirements so that the
appropriate objectives can be met:
• Assess compliance with NPDES permit conditions
• Determine compliance with State water quality standards
• Evaluate quality of self-monitoring data
• Assess adequacy of self-monitoring procedures
• Document existence or lack of toxic conditions
• Identify need to perform a Toxicity Identification Evaluation (TIE) and/or a Toxicity
Reduction Evaluation (TRE)
• Develop permit limits.
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Chapter Eight Toxicity
In the case of a PAI, the laboratory performing the WET tests is evaluated, as well as the
NPDES permittee. This type of inspection requires more extensive information than is
presented in this section. The inspector is therefore referred to Environmental Protection
Agency's (EPA) Manual for the Evaluation of Laboratories Performing Aquatic Toxicity Tests
(EPA/600/4-90/031) for the protocol to perform a PAI.
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Chapter Eight Toxicity
8. TOXICITY
B. Requirements of WET Testing
Types of WET Testing
WET tests are techniques to determine the toxicity of a permittee's discharge or effluent by
measuring the responses of organisms to solutions containing various percentages of effluent
and dilution water. The test designs vary, depending on how the results are to be used. Test
designs may vary in duration (acute or chronic) or in the way in which the effluent contacts the
organism (flow-through, static, static renewal). However, WET testing is usually performed as
a definitive (as opposed to a range finding or screening) test.
In a definitive test, several groups (replicates) of organisms are exposed for a predetermined
length of time to solutions containing various proportions of effluent and dilution water. The
response of each organism in each test concentration is observed and recorded, and the
number of responses is analyzed in relation to the concentrations of effluent to which the
organisms were exposed.
WET testing may be performed as either acute or chronic tests. The terms acute and chronic
refer to the length of time that the organisms are exposed to the toxicant. The duration of the
tests should be specified in the NPDES permit. Generally, acute tests measure short-term
effects with impacts usually resulting in death or extreme physiological disorder. A response
observed in 96 hours or less typically is considered acute. Chronic tests involve a stimulus
that lingers or continues for a relatively long period, often one-tenth of a lifespan or more.
Chronic should be considered a relative term depending on the lifespan of an organism. A
chronic effect may result in death, stunted growth, or reduced reproductive rates.
Common test responses indicating the presence of toxic conditions include:
• Death — Increase in number of organisms killed by a test solution compared to the
control
• Growth — Reduction in growth compared to the control
• Reproduction — Reduction in reproductive rates compared to the control
• Terata — Increase in number of gross abnormalities shown in early life stages
compared to the control.
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Chapter Eight Toxicity
WET tests are also described according to the way in which organisms are exposed to test
solutions. The terms flow-through, static renewal, and static are most commonly used to
describe how often the test solutions are renewed. In a flow-through test, effluent and dilution
water are mechanically renewed continuously. This test setup requires specialized equipment
(a serial or proportional dilutor or syringe pumps) and is more costly to operate than a static
test. In a static renewal test, the test solutions are replaced periodically (usually daily) with
fresh effluent and dilution water. In a static test, the solutions used at the start of the test are
not replaced for the test's duration. Both static renewal and static tests require only basic
equipment. The method of test solution renewal should be specified in the NPDES permit.
WET Test Components
WET tests consist of a number of components, as shown below:
• Effluent
• Dilution water
• Test Apparatus
• Test organisms
• Reference Toxicants
• Test results.
In simple terms, effluent and dilution water are combined in the test system with test
organisms to produce test results. Each component must be of a specific quality for
successful toxicity testing. It is the inspector's job to determine (insofar as possible) from the
information available, that the test components adhere to the standards specified in the
NPDES permit or accepted reference method. Review of the permittee's sampling logbook,
chain of custody forms, and contract lab reports should provide most of the information
necessary to assess the quality of the test components.
Each component has specific requirements (e.g., sample location for the effluent, dilution
water constituents, choice of test apparatus materials). Accurate and reproducible test results
can only be expected when the critical test components are handled properly. It is, therefore,
very important to understand the relationships between these test components and the critical
factors that determine the acceptability of each from a quality assurance standpoint. Critical
factors that would likely be encountered during an NPDES inspection are described in the
following sections.
Effluent
Effluent sampling strategy will usually be specified in the NPDES permit. Effluent samples
must be representative of the entire discharge and free of contamination from other sources.
If holding is necessary, the samples must be stored under strict conditions (4°C) and for
limited times (less than 36 hours) so that no appreciable change in toxic characteristics occurs
before testing.
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Chapter Eight Toxicity
The type and frequency of samples taken (e.g., grab, composite) must be consistent with
those required in the permit. For flow-through tests that are not done by pumping effluent
directly into dilutors, daily sample sizes must be sufficient to supply the dilutor for periods
ranging from 24 to 36 hours. This volume will depend on the type of test being conducted
and the number of dilutions being run. For static renewal tests, daily sample volumes should
be sufficient to replenish all dilutions in the test series and to provide separate vials of the
dilutions to allow for Dissolved Oxygen (DO), pH, salinity, and other chemical analyses without
contamination of the test dilutions. This volume will depend on the type of test being
conducted and dilutions being run. Table 8-1 provides guidance as to representative sampling
strategies for various situations.
Sample containers for large volumes of effluent should be either covered fiberglass or
unsealed stainless steel tanks. Small volumes of effluent can be stored in reusable glass jugs
or non-reusable Cubitainers or plastic milk jugs.
Samples for onsite tests should be used immediately when practical, but must be used within
36 hours of collection. It is usually not possible to refrigerate the large volume samples (200
liters or more) that are required for flow-through fish tests, but all other samples should be
either iced or refrigerated if they are not to be used immediately.
Samples to be used for offsite tests should be iced for shipment and refrigerated (4°C) upon
receipt by the testing laboratory. As a minimum requirement in all cases, tests should be
initiated within 36 hours of collection. In the case of short-term chronic, tests, samples taken
on days one, three, and five may be held for a longer period of time to complete the test. In
no case should any preservative be added to samples to be tested for toxicity.
Dilution Water
The choice of dilution water is generally specified in the NPDES permit and depends on the
purpose of the toxicity test. Synthetic dilution water is used to evaluate the inherent toxicity of
the effluent. Dilution water from the receiving stream or a nontoxic equivalent is used to test
for interactions after discharge. Under no circumstances should the dilution water cause any
toxic responses in test organisms. A lack of toxic responses in control organisms is evidence
of the suitability of the dilution water. Control organisms should have less than or equal to 10
percent mortality in acute tests and less than or equal to 20 percent mortality for chronic tests.
EPA manuals describe various techniques for the preparation of synthetic dilution water which
may be necessary to use if the natural receiving water exhibits unacceptable levels of toxicity.
Dilution water obtained from receiving waters should be immediately used for testing. If it will
not be used within 24 hours, it should be refrigerated (4°C) as soon as it is collected. In any
case, the receiving water should be used within 36 hours of collection. The location from
which the dilution water was obtained should be noted in the permittee's sampling log. It
should be upstream and out of the influence of the outfall. The location should be free of
other sources of contamination (e.g., other outfalls).
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Chapter Eight Toxicity
Test System
WET tests may be performed in a fixed or mobile laboratory. Depending on the scope of the
program, facilities may include equipment for rearing, holding, and acclimating organisms.
Temperature control is achieved using circulating water baths, heat exchangers, or
environmental chambers. Appropriate dilution water may be ground water, surface water,
reconstituted water, or dechlorinated tap water. Holding, acclimation, and dilution water
should be temperature controlled and aerated whenever possible. Air used for aeration must
be free of oil and fumes; filters to remove oil in air are desirable. Test facilities must be well-
ventilated and free of fumes. During holding, acclimating, and testing, test organisms should
be shielded from external disturbances.
Any materials that come into contact with either effluent or dilution water must not release,
absorb, or adsorb toxicants. A number of different choices for test equipment are available.
Glass and No. 304 or 306 stainless steel are generally acceptable for freshwater holding,
mixing, and test chambers. Stainless steel, however, is not acceptable for saltwater systems.
Square-sided glass aquaria should be held together with small beads of silicone adhesive,
with any unnecessary adhesive removed from inside the aquaria. If stainless steel containers
are used, they must be welded, not soldered. Other specialized containers of NITEX or
TEFLON are also acceptable. Tanks for storing effluents and dilution water may also be
made of fiberglass. All containers or tubes made of these materials are reusable with
appropriate cleaning (see below).
Polyethylene, polypropylene, polyvinyl chloride, polystyrene, and TYGON may also be used
for containers or tubing, but should be checked for toxicity before being used. Because these
materials may absorb toxicants during a test, their reuse is discouraged to prevent absorbed
toxicants from leaching into new effluent or dilution water.
Copper, galvanized metal, brass, lead, and rubber must not contact the testing solutions at
any time.
New plasticware (from a known nontoxic source) can be used after rinsing with dilution water.
New glassware should be soaked overnight in dilute (20 percent) nitric or hydrochloric acid,
rinsed in tap water, and then rinsed with dilution water before use.
Glassware and stainless steel components that must be reused should be soaked in detergent
and scrubbed (or washed in a laboratory dishwasher), rinsed twice with tap water, rinsed with
dilute acid, rinsed twice with tap water, rinsed with full strength acetone, rinsed twice with tap
water, and then rinsed with dilution water before use. Glassware for algae tests should be
neutralized in sodium bicarbonate before use.
Test Organisms
Organisms used for toxicity testing are limited to certain species for which there are
established testing protocols. Species commonly used in biomonitoring include daphnids,
mysids, fathead minnows, silversides, and algae. The life stage, source, acclimation and
feeding procedures, presence of disease, and the number of organisms placed in test
chambers all affect the degree to which organisms respond to toxicants. Therefore, it is
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Chapter Eight Toxicity
important that these factors be standardized as much as possible. Appendix H summarizes
test conditions for various types of tests and organisms.
The inspector should ascertain, as closely as possible, that the following procedures are being
observed.
• The correct organisms must be utilized in the test (most often as specified in the
NPDES permit). "Wild" organisms are rarely appropriate in WET testing. Test
organisms used in toxicity testing must be of known history, free of disease, and
acclimated to test conditions. Culture information should be recorded. Test organisms
must also be of the appropriate age. The appropriate number of organisms must be
used in each test vessel.
• Test organisms should be fed according to the requirements for the particular type of
test. When feeding is necessary, excess food should be removed daily by aspirating
with a pipette, to avoid problems such as food buildup leading to excessive oxygen
demand.
• A daily log should be kept by the lab of feeding, reproduction, growth, mortality, and
any abnormal behavioral observations.
• The following procedures are being observed (by the contract laboratory) for holding
test organisms:
- Quarantines new test organisms for at least 10 days if received from an outside
source of unknown quality or for 48 hours if test organisms are obtained from a
quality stock.
- Maintains DO levels above 40-percent saturation for warm water species and above
60-percent saturation for cold water species.
• The laboratory should record the source of test organisms (hatchery, in-house, or
elsewhere), as well as holding conditions (temperature, dissolved oxygen).
• Test organisms should be handled as little as possible to minimize stress:
- Dip nets should be used for large organisms
- Pipettes should be used for transferring small organisms such as daphnids and
midge larvae.
Reference Toxicants
Reference toxicants are used to establish the relative sensitivity of the test organisms. A
laboratory performs a definitive 24- or 48-hour static toxicity test with the reference toxicant to
establish an average response. Reference toxicants available from the USEPA Environmental
Monitoring Systems Laboratory (EMSL), Cincinnati, Ohio, include cadmium chloride and
copper sulfate. Reference toxicants can also be prepared by the testing laboratory. An
attempt should be made to match the type of reference toxicant used (e.g., metal or
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Chapter Eight Toxicity
chlorinated organic) to the major pollutant in the wastewater tested. Reference toxicant data
should be included with the contract lab report.
Recordkeeping and Data Reporting
Proper recordkeeping is essential to an effective program. Chain-of-custody procedures
should consistently be used to document sample transfer. The permittee should maintain a
sample log containing information as to the date, time, and type of sample taken as well as
the sampler's name. Unusual conditions should be noted. When evaluating the contract lab's
data reporting, the inspector should verify that the following are included:
• Summary of test results, description of test conditions, material tested, and other data
for quality assurance
• Methods used for all chemical analyses
• Average and range of acclimation temperature and test temperature
• Any deviation from standard test methods
• Any other relevant information.
It may be beneficial for the contract lab to have a copy of the permittee's NPDES permit,
including any modifications. By having a copy of the permit, the lab can better ensure that
proper test procedures are being followed.
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Toxicity
Table 8-1
Recommended Sampling Strategies for Continuous and Intermittent
Discharges for Flow-Through, Static Renewal, and Static Toxicity Tests
CONTINUOUS DISCHARGE
Test Type
Flow-through*
Static renewal
Static
Retention Time
<14 Days
Two grab samples daily (early a.m. and
late p.m.)
Four separate grab samples each day
for four concurrent tests
Four separate grab samples on first day
for four concurrent tests
Retention Time >14 Days
One grab sample daily
One grab sample daily
One grab sample on first day
For flow-through tests, it is always preferable to pump effluent directly to the dilutor.
INTERMITTENT DISCHARGE
Test Type
Flow-through
Static renewal
Static
Continuous Discharge
During 1 or 2 Adjacent
8-Hour Shifts
One grab sample midway
through shifts daily
One grab sample midway
through shifts daily
One grab sample midway
through shifts on first day
Discharge From
Batch Treatment
One grab sample of
discharge daily
One grab sample of
discharge daily
One grab sample of
discharge on first
day
Discharge to Estuary
on Outgoing Tide
One grab sample of
discharge daily
One grab sample of
discharge daily
One grab sample of
discharge on first day
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*** NOTES ***
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Chapter Eight Toxicity
8. TOXICITY
C. Analysis of Results
In general, the valid interpretation of test results requires that mortality in controls be limited,
the conditions specified in the previous sections be met, and the results be consistent with
response patterns normally observed in toxicity tests (e.g., increasing mortality with increasing
concentrations). If any of these three general conditions are not met, the test results are
invalid. However, there are exceptions, as discussed later.
In general, survival in controls must exceed survival in all other test chambers for both acute
and chronic tests. If it does not, calculation of the toxicity due to increasing effluent
concentration is at best an approximation of effluent toxicity. In any case, mortality in controls
should not exceed 10 percent for acute toxicity tests and 20 percent for chronic test (or other
values as required by States through their regulations). If control survival does not meet 90 or
80 percent for an acute or chronic test, respectively, then results should not be used for
calculating summary statistics, and a determination of compliance using the test results cannot
be made.
Each protocol has specified criteria to achieve acceptable ranges of control survival:
temperature, dissolved oxygen concentration, salinity, pH, light intensity and duration of
photoperiod, organism loading (numbers or weight per volume), feeding, and cleaning
procedures. Summary tables of selected EPA methods are included as Appendix H. Tests
not meeting the control criteria to achieve survival, growth, or reproduction are not valid.
Tests not meeting the other acceptability criteria in these tables should be reviewed with
caution and referred to the regional biologist. The inspector should review the EPA methods
manual for a more extensive discussion of each of these factors. The EPA methods manuals
are the following:
• Short-Term Methods for Estimating the Chronic Toxicity of Effluents and Receiving
Waters to Freshwater Organisms, EPA/600/4-89/001
• Short-Term Methods for Measuring the Acute Toxicity of Effluent and Receiving Waters
to Freshwater and Marine Organisms, EPA/600/4-90/027F
• Short-Term Methods for Estimates the Chronic Toxicity of Effluents and Receiving
Waters to Marine and Estuarine Organisms, EPA/600/4-87/028.
The expected result in all toxicity tests is a greater number of organism responses with
increasing effluent concentrations. On many occasions, this increasing response is observed
as one concentration eliciting no responses and the next higher concentration having 100
percent responses. This pattern is particularly obvious with acute tests. In other cases, the
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test organisms in more than one effluent dilution may exhibit a partial response (between 0
and 100 percent).
When test results do not meet the expected pattern, the test may be invalid. Questionable
results in an acute test include:
• Higher mortalities in lower concentrations than in higher concentrations of effluent
• 100 percent mortality in all effluent dilutions
• Greater percent mortality in the control than in the lower dilutions of effluent.
Questionable results in a chronic test include:
• Greater growth or reproduction or fewer terata at higher concentrations of effluent than
at lower concentrations
• No growth or reproduction or 100 percent terata at all effluent concentrations
• Less growth or reproduction or more terata in controls than in lower effluent
concentrations.
When any of these abnormalities occur (outside of experimental error), the results and test
conditions should be reviewed by the regional'biologist. It should be recognized, however,
that often there will be minor variations in test results. For example, Ceriodaphnia dubia
reproduction may be higher at intermediate concentrations that are not toxic but provide a
greater food resource than lower concentrations. Thus, variations should not always be used
to eliminate otherwise valid results. However, if the normally expected pattern is not found,
summary statistics calculated on the results should be assessed with caution.
Under some circumstances, compliance may still be determined with abnormal test results. If,
for example, 100 percent responses were found in all effluent dilutions but the control was
within the acceptable range, the appropriate toxicity measure would have to be below the
most dilute solution tested. Similarly, if no responses are found in the toxicity test, the effluent
can be deemed nontoxic at 100 percent effluent.
The test results need to be expressed such that compliance with the permittee's WET limits
can be determined. The following definitions may help the inspector to interpret the results:
• The LC50 (for lethal concentration) is the calculated percentage of effluent (point
estimate) at which 50 percent of the organisms die in the test period. Usually, the LC50
is calculated statistically by computer programs that fit the response curve to a
mathematical function. Computer-based calculation procedures usually print an
estimate of the error associated with the LC50 estimate.
• The EC50 (for effect concentration) is the calculated concentration (point estimate) at
which 50 percent of the organisms show a particular effect (not necessarily death).
For some species (e.g., Ceriodaphnia dubia) where the point of death is not certain,
immobility is often used as a surrogate for death. Results for responses like the
immobility responses in Daphnia may be reported as an EC50 (calculated in the same
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Chapter Eight Toxicity
manner as the LC50). Often, however, no distinction is made between the EC50 and the
LC50 when the response is a surrogate for death.
• The No Observable Effect Concentration (NOEC) is the highest tested concentration at
which the organisms' responses are not statistically different from the control
organisms' responses. The NOEC [like the Lowest Observable Effect Concentration
(LOEC) and Chronic Value (ChV) defined in the following paragraphs] is normally
determined only for chronic tests.
• The LOEC is the lowest tested concentration at which organisms' responses are
statistically different from controls. The ChV is the calculated geometric mean of the
NOEC and LOEC (the square root of the product of the NOEC and LOEC).
• The Inhibition Concentration) (IC25) is the calculated percentage of effluent (point
estimate) at which the organisms exhibit a 25 percent reduction in a non-quantal
biological measurement such as fecundity or growth.
• The percent response at a criterion concentration is reported. For example, the permit
or standard may prohibit toxicity at 100 percent effluent or less. In this case, predicted
percent response at 100 percent effluent would be reported.
There is an inverse relationship between toxicity and the effluent concentration percentage
causing a toxic response. In other words, the same toxicity test response (e.g., LC50) at lower
percentages of effluent (i.e., more dilution) indicates higher toxicity than test results at higher
percentages of effluent (i.e., less dilution). A Toxic Unit (TU), which is directly proportional to
toxicity, is sometimes used to express the effluent's toxicity. TUs are defined as 100/LC50 for
acute or 100/NOEC for chronic when the LC50 or NOEC is expressed as percent effluent. An
effluent with an LC50 of 50 percent effluent has an acute toxicity of 2 Acute Toxic Units (TUa).
Similarly, an effluent with a NOEC of 25-percent effluent has a chronic toxicity of 4 Chronic
Toxic Units (TUC). The major advantage of using toxic units to express toxicity test results is
that toxic units increase linearly as the toxicity of the effluent increases. So an effluent with a
TUa of 4 is twice as toxic as an effluent with a TUa of 2. A second advantage of using toxic
units is that they are directly analogous to constituent concentrations and can be used in
waste load allocations with the same equations as individual constituents.
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Chapter Eight Toxicity
*** NOTES ***
8-14
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9. PRETREATMENT
Contents Page
A. Review of the General Pretreatment Regulations
Development of 40 CFR Part 403 . . : 9-1
Approval Authority Responsibilities 9-2
Control Authority Responsibilities 9-3
Industry Responsibilities 9-6
B. Pretreatment Compliance Inspections (PCIs) and Audits
Scope of PCIs and Audits 9-15
PCI Checklist Components 9-17
Summary of Audit Checklist Components 9-18
C. References
References 9-21
List of Tables
9-1 Summary of the General Pretreatment Regulations 9-8
9-2 Categorical Pretreatment Standards 9-13
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Chapter Nine Contents
NOTES
9-ii
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9. PRETREATMENT
A. Review of the General Pretreatment
Regulations
Development of 40 CFR Part 403
The Clean Water Act (CWA) requires Environmental Protection Agency (EPA) to promulgate
regulations to control the discharge of pollutants to the Nation's waters to preserve their
physical, chemical, and biological integrity. The National Pollutant Discharge Elimination
System (NPDES) program is the primary regulatory mechanism developed to control
point-source discharges to the surface waters of the United States. The National Pretreatment
Program is the mechanism developed to regulate nondomestic users who discharge pollutants
to Publicly Owned Treatment Works (POTWs) that could pass through or interfere with the
treatment plant, threaten worker health and safety, or contaminate sludges.
The General Pretreatment Regulations [40 Code of Federal Regulations (CFR) Part 403] were
promulgated on June 26, 1978. The regulations were revised and repromulgated on January
28, 1981. Since publication of the rule in 1981, the regulations have continued to be revised.
Amendments have been made to the regulations to clarify some aspects and to respond to
the findings of the Pretreatment Implementation Review Task Force (PIRT) study conducted in
1984. Additional regulatory changes were promulgated on July 24, 1990, (Federal Register
30082) in response to recommendations made in the Domestic Sewage Study (DSS). A
summary of the General Pretreatment Regulations is provided in Table 9-1. Major technical
changes resulting from final regulatory amendments or court decisions are noted in this table.
The purpose of the General Pretreatment Regulations is to protect POTWs and the
environment from the damage that may result from discharges of pollutants to sanitary sewer
systems. The three specific objectives cited in 40 CFR 403.2 of the General Pretreatment
Regulations are to:
• Prevent the introduction of pollutants that would cause interference with the POTW or
limit the use and disposal of its sludge
• Prevent the introduction of pollutants that would pass through the treatment works or
be otherwise incompatible
• Improve the opportunities to recycle or reclaim municipal and industrial wastewaters
and sludges.
In addition, improved POTW worker health and safety and reduction of influent loadings to
sewage treatment plants are further objectives of pretreatment. Briefly stated, the definitions
for interference and pass through are the following (see 40 CFR 403.3 for the exact
definitions):
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Chapter Nine Pretreatment
• Interference is a discharge that alone or in conjunction with other discharges, disrupts
the POTW or sludge processes, uses, and disposal, and therefore in turn causes
violation of any requirement of the POTW's NPDES permit or prevents the POTW from
using its chosen sludge use or disposal practice.
• Pass through is a discharge that exits the POTWs to waters of the United States in
quantities or concentrations which, alone or in conjunction with other discharges,
causes a POTW NPDES permit violation.
The General Pretreatment Regulations detail the procedures, responsibilities, and
requirements of EPA, States, POTWs, and industries. To achieve the objectives of the
regulations, implementation of the program by all regulated entities must be accomplished. In
the next three sections, the specific responsibilities of each are explained.
Guidance manuals developed to assist EPA Regional Offices, States, POTWs, and industries
with implementation of the General Pretreatment Program are listed in Section C,
"References," of this chapter. In addition, policy memorandums from the EPA Office of Water
Enforcement and Permits on pretreatment issues are listed.
Approval Authority Responsibilities
Two terms are important in understanding the General.Pretreatment Regulations: "Control
Authority" and "Approval Authority." Control Authority directly regulates the significant
industrial users discharging to a POTW; Approval Authority oversees the development and
implementation of POTW pretreatment programs and, for POTWs without an approved
pretreatment program, is also the Control Authority that regulates industrial discharges to the
POTW. The EPA Regional Office is the Approval Authority until a State is approved to
administer the pretreatment program. However, once a State is approved, the EPA Regional
Office maintains oversight responsibilities.
A pretreatment program is administered through the EPA Regional Office or a State with
NPDES and pretreatment approval. The principal tasks for which an Approval Authority (EPA
Regional Office or delegated State) is responsible are the following:
• Reviewing and approving POTW pretreatment programs and major modifications (see
"Control Authority Responsibilities" for what Control Authority program development
entails).
• Overseeing POTW program implementation, i.e., Pretreatment Compliance Inspections
(PCIs), audits, and annual report reviews.
• Providing POTWs with technical assistance on the requirements of the General
Pretreatment Regulations, categorical pretreatment standards, and POTW pretreatment
program requirements.
• Notifying POTWs of new and existing program requirements.
• Determining SIU and POTW compliance with all applicable Federal requirements.
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Chapter Nine Pretreatment
• Applying and enforcing pretreatment standards and requirements at industries
discharging to POTWs that do not have an approved local pretreatment program.
• Initiating enforcement action against noncompliant POTWs or industries.
Part 403.10 of the General Pretreatment Regulations identifies the requirements a State must
meet to receive approval of the pretreatment program as part of its NPDES authority, that is,
to become an Approval Authority. For States preferring to assume the responsibility of directly
regulating industries discharging to POTWs and, hence, being considered the Control
Authority in lieu of POTWs within the State, 40 CFR 403.10(e) provides that option.
Control Authority Responsibilities
Control Authority pretreatment program development and implementation requirements must
be included in the NPDES permit of POTWs required to develop programs. Those
requirements will thereby become an enforceable component of the permit. Part 403.8 of the
General Pretreatment Regulations details the responsibilities of a POTW during the
development of a pretreatment program. Additional information on the responsibilities of
Control Authorities is provided in the EPA Guidance Manual for POTW Pretreatment Program
Development (1993) and subsequent EPA guidance manuals.
The Control Authority program is submitted to the Approval Authority, either the EPA Regional
Office or the approved State. Once approval has been received, the NPDES permit must be
amended to require the Control Authority to implement the program.
Before a Control Authority pretreatment program is approved, the Approval Authority is the
Control Authority for industries discharging to the POTW. After program approval, the Control
Authority becomes responsible for implementing the requirements specified in the General
Pretreatment Regulations [40 CFR 403.8(f)], the POTW pretreatment program, and the
requirements of the NPDES permit (the permit must be complied with regardless of program
approval). To fully implement the pretreatment program throughout the entire service area,
the Control Authority has responsibilities related to several specific areas:
• Legal authority
- Deny or condition new or increased discharges.
- Require industrial users to comply with applicable pretreatment standards and
requirements.
- Require development of compliance schedules.
- Carry out all inspection, surveillance, and monitoring procedures to determine
industrial user compliance.
- Enter premises of industrial users.
- Apply Federal pretreatment standards to IDs.
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Chapter Nine Pretreatment
- Seek injunctive relief for noncompliance.
- Seek or assess civil or criminal penalties of at least $1,000 a day per violation.
- Immediately halt a discharge that presents or appears to present an imminent
endangerment to the health or welfare of persons or to the environment or that
threatens to interfere with the POTW's operation.
- Comply with confidentiality requirements.
- Develop and enforce an adequate sewer use ordinance.
- Control through permit order, or similar means, the contribution to the POTW by
each industrial user. Individual control mechanisms that contain minimum required
elements must be issued to significant industrial users.
• Pretreatment standards
- Identify and locate all possible industrial users that may be subject to the
pretreatment program.
- Identify the character and volume of pollutants contributed to the POTW.
- Establish and periodically reevaluate local limits to ensure protection of the POTW
from interference or pass through and to ensure the use or disposal of POTW
sludge.
- Notify all industrial users of appropriate pretreatment standards, any changes to the
regulations, and requirements of the Resource Conservation and Recovery Act
(RCRA).
- Update the industrial survey to identify new industries that should be regulated by
the POTW pretreatment program, and identify changes in manufacturing processes
and wastewater discharge characteristics at existing facilities.
- Comply with public participation requirements.
• Industrial user compliance and enforcement
- Establish reporting, inspection, and monitoring requirements and procedures to
enable evaluation of compliance.
- Inspect and sample industrial users. At a minimum, significant industrial users must
be sampled and inspected at least once a year.
- Evaluate each significant industrial user at least once every 2 years for the need for
a slug discharge control program.
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Chapter Nine Pretreatment
- Perform sampling and analysis in a manner to produce evidence admissible in
enforcement proceedings or in judicial actions.
- Develop and implement an enforcement response plan to guide compliance
evaluation and enforcement activities.
- Evaluate industry compliance by reviewing and analyzing self-monitoring reports
and Control Authority monitoring.
- Investigate instances of noncompliance.
- Initiate appropriate enforcement action to bring users into compliance.
- Establish other procedures as required and/or determined to be needed to regulate
the significant industries discharging to the POTW.
• Public participation
- Publish at least annually, in the local newspaper with the greatest circulation, a list
of the industrial users that were in significant noncompliance within the past 12
months as defined in 40 CFf? 403.8(f)(2)(vii).
- Notify the public of any changes to the sewer use ordinance or local limits after
approval by the Approval Authority.
- Submit pretreatment program modifications to Approval Authority.
• Data management
- Maintain records of pertinent industrial user activities and compliance status.
- Maintain a current understanding of the categorical pretreatment standards and
General Pretreatment Regulations, and notify industries of any changes.
- Provide the Approval Authorities with any reports required.
• Resources
- Provide adequate resources and qualified personnel for program implementation.
As pretreatment needs change, the Control Authority may need to revise the approved
program. When this occurs, the Control Authority should submit the modifications to the
Approval Authority for review and approval.
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Chapter Nine Pretreatment
Industry Responsibilities
Industrial dischargers to POTWs must comply with the following:
• Prohibited discharge standards—The general and specific prohibited discharge
standards (40 CFR 403.5) noted in Table 9-1.
• Appropriate pretreatment standards—Categorical pretreatment standards (40 CFR Part
405-471), State requirements, or locally developed discharge limitations as per 40 CFR
403.5.
• Reporting requirements—As specified in 40 CFR 403.12 and/or by the POTW. The
requirements provided in 40 CFR 403.12 are summarized in Table 9-1.
The types of industrial facilities that are categorical industries are listed in Table 9-2. EPA has
developed categorical pretreatment standards for these industries based on the type of wastes
produced by the manufacturing processes at each type of industry, the wastewater control
technologies available to the industry, and economic considerations. The categorical
pretreatment standards developed apply to the wastewaters from specific manufacturing
processes. The standards apply at the point of discharge from the pretreatment unit for the
regulated process, or if there is no pretreatment unit, they apply at the end of the regulated
process.
Where the Control Authority has determined that specific limitations for certain pollutants of
concern are needed to protect the POTW from interference, pass through, and sludge
contamination, the Control Authority must develop and enforce such limitations. These local
limitations generally are applied at the point where the industrial facility discharges to the
POTW.
An industry must meet the more stringent pretreatment standard for each pollutant. For a
categorical industry, this will be the categorical pretreatment standard or a local limit for each
pollutant regulated. If the point at which the Control Authority's limitation applies is not the
same as the point at which the categorical pretreatment standard applies, either a calculation
to adjust the categorical pretreatment standard will have to be used to compare the discharge
limitations or sampling must be conducted at both points so that compliance with categorical
standards and local limits can be determined.
When evaluating the pretreatment standards to determine the appropriate limitation, note that
different categorical pretreatment standards were developed for each type of industry. If the
industry combines the flows from more than one regulated process or combines a regulated
process flow with other flows before these wastes are treated, the Control Authority and the
industry must adjust the categorical pretreatment standard using the Combined Wastestream
Formula (CWF). The equation is provided in 40 CFf?403.6(e) of the General Pretreatment
Regulations. If the wastewaters are mixed after treatment, the categorical pretreatment
standards must still be adjusted, in this case by flow weighted averaging of all flows
introduced prior to the sample point. In either case, the resulting alternative limit cannot be
set below the level of detection for that pollutant. Additional information on the combined
wastestream formula and the flow weighted averaging formula is provided in EPA's Guidance
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Chapter Nine Pretreatment
Manual for Implementing Production-Based Pretreatment Standards and the Combined
Wastestream Formula (1985).
Categorical industries have specific reporting requirements as per 40 CFR 403.12. A
summary of the reports that categorical industries are required to submit is provided in Table
9-1. A Control Authority may require additional reports from all industries discharging to the
system, including categorical industries.
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Chapter Nine Pretreatment
Table 9-1
Summary of the General Pretreatment Regulations
403.1 Purpose and Applicability
403.2 Objectives of General Pretreatment Regulations
403.3 Definitions
403.4 State or Local Law
The Federal General Pretreatment Regulations are not meant to affect any state or
local regulatory requirements as long as these requirements are at least as stringent
as the Federal regulations.
403.5 National Pretreatment Standards: Prohibited Discharges
This section specifies general and specific prohibited discharge standards that Control
Authorities must incorporate into their pretreatment programs. The general
prohibitions specify that pollutants introduced into POTWs by a nondomestic source
shall not pass through the POTW or interfere with the operation or performance of the
works. The section provides that Control Authorities required to develop local
pretreatment programs and POTWs where interference and pass through are likely to
recur develop and enforce specific limitations (local limits) to implement the general
prohibitions against interference, pass through, and sludge contamination.
The specific prohibitions specify prevention of discharge of pollutants that cause any
of the following at the POTW:
• Fire or explosion hazard, including no discharge with a closed-cup flashpoint of
less than 60°C (140°F) using test methods in 40 CFR 261.21
• Corrosive structural damage (no pH<5.0)
• Obstruction to the flow in the POTW
• Interference
• Heat causing inhibition, of biological activity and temperatures at the POTW
treatment plant to exceed 40°C (104°F)
• Petroleum oils, nonbiodegradable cutting oils, or products of mineral oils in
amounts that will cause interference or pass through
• Fume toxicity or reactivity
• Trucked or hauled pollutants except at designated discharge points.
Additionally, industrial users are provided with an affirmative defense (if specified
conditions are met) for actions brought against them for alleged violations of the
general or specific prohibitions contained in this section.
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Chapter Nine Pretreatment
Table 9-1
Summary of the General Pretreatment Regulations
(Continued)
403.6 National Pretreatment Standards: Categorical Standards
This section discusses development and implementation of categorical pretreatment
standards including, but not limited to, compliance deadlines, concentrations and
mass limits, prohibition of dilution as a substitute treatment, and the Combined
Wastestream Formula (CWF) to determine discharge limitations.
403.7 Revision of Categorical Pretreatment Standards to Reflect POTW Removal of
Pollutants
This section (referred to as the removal credits provision) provides the criteria and
procedures to be used by a POTW in revising the pollutant discharge limits specified
in categorical pretreatment standards to reflect removal of pollutants by the POTW.
403.8 Control Authority Pretreatment Programs: Development by Control Authority
This section covers the requirements for pretreatment program development by a
Control Authority. Included in this section are criteria for determining which POTWs
must develop pretreatment programs, incorporation of approved programs and
compliance schedules into NPDES permits, deadlines for program approvals, and
program and funding requirements. 403.8(f) sets out the requirements of a POTW
program. Specifically, it requires the Control Authority to have sufficient legal
authority to enforce the approved pretreatment program. The section also discusses
that all Control Authorities with approved programs, or programs under development,
must develop and implement procedures to ensure compliance with the requirements
of a pretreatment program.
403.9 Control Authority Pretreatment Programs and/or Authorization to Revise Pretreatment
Standards: Submission for Approval
This section discusses requirements and procedures for submission and review of
Control Authority pretreatment programs. Included in this section are discussions of
conditional program approval, approval authority action, and notification where
submissions are defective.
403.10 Development and Submission of NPDES State Pretreatment Programs
This section discusses requirements and procedures for submission and review of
NPDES State pretreatment programs. Included in this section are discussions of
approvals and deadlines for State programs, legal authority, program and funding
requirements, and contents of program submissions.
403.11 Approval Procedures for Control Authority Pretreatment Programs and Revision of
Categorical Pretreatment Standards
This section provides the administrative procedures for the review and approval or
denial of Control Authority pretreatment program submissions and requests for
removal credit authority.
403.12 Reporting Requirements for Control Authorities and Industrial Users
This section presents reporting requirements for Control Authorities and industrial
users. Reports required by industrial users include the following:
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Chapter Nine Pretreatment
Table 9-1
Summary of the General Pretreatment Regulations
(Continued)
403.12 (Continued)
• Baseline Monitoring Report (BMR). Due to the Control Authority within 180 days
of the effective date of the categorical pretreatment standards (40 CFR 403.6).
In addition, new source BMR reporting requirements are discussed in this
section.
• Compliance schedule progress reports. Due to the Control Authority within 14
days of completion of compliance schedule milestones or due dates.
• 90-day compliance report. Due to the Control Authority within 90 days of the
compliance date of the categorical standards.
• Periodic reports on continued compliance. Due to the Control Authority at least
semiannually, usually in June and December after the compliance date.
• Notices of potential problems including slug loadings. Due to the Control
Authority immediately upon identification of discharges, including slug loadings
that could cause problems to the POTW for both noncategorical and categorical
industries.
• Notice of changed discharge. Due to the Control Authority from categorical and
noncategorical users in advance of any significant change in volume or
character of pollutants discharged.
• Notice of violation and resampling. Notification due to the Control Authority
within 24 hours of noting a violation; results of resampling due within 30 days.
• Notification of hazardous waste discharge. Notification to the POTW, EPA, and
State Hazardous Waste authorities of the hazardous wastes discharges to the
POTW.
Reports required from Control Authorities include the following:
• Compliance schedule (for development of pretreatment programs) progress
reports
• Annual POTW reports.
Also discussed in detail in this section are monitoring requirements for industrial users
and signatory and recordkeeping requirements for Control Authorities and industrial
users.
403.13 Variances from Categorical Pretreatment Standards for Fundamentally Different
Factors
This provision allows an industrial user, or any interested person, to request a
variance for the establishment of limits either more or less stringent than that required
by a categorical pretreatment standard. The primary criterion required for approval of
this variance is that the factors relating to the industrial user's discharges be
fundamentally different from factors considered by EPA in establishing categorical
pretreatment standards for these discharges.
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Chapter Nine Pretreatment
Table 9-1
Summary of the General Pretreatment Regulations
(Continued)
403.14 Confidentiality
This section covers confidentiality requirements and prohibitions for EPA, States, and
Control Authorities. Effluent data are available to the public without restriction.
403.15 Net/Gross Calculation
This provision provides for adjustment of categorical pretreatment standards to reflect
the presence of pollutants in the industrial user's intake water.
403.16 Upset Provision
This provision is consistent with the NPDES regulations and allows an upset of an
industry's pretreatment system (which meets the conditions of an upset as specified
in this provision) to be an affirmative defense to an action brought for noncompliance
with categorical pretreatment standards. The industrial user shall have the burden of
proof for such a defense.
403.17 Bypass
This provision requires industrial users to operate their treatment systems at all times
and includes criteria for allowing a bypass to occur and notification procedures for
both an anticipated and unanticipated bypass.
403.18 Modification of Control Authority Pretreatment Programs
This provision specifies procedures and criteria for "minor" and "substantial"
modifications to approved Control Authority pretreatment programs and incorporation
of substantial modifications into the Control Authority NPDES program.
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Chapter Nine
Pretreatment
Table 9-1
Summary of the General Pretreatment Regulations
(Continued)
Appendix A Program Guidance Memorandum
This memorandum summarizes the Agency's policy on the use of construction grants
for treatment and control of combined sewer overflows and storm water discharges.
Appendix B 65 Toxic Pollutants
This appendix lists the 65 classes of toxic pollutants that are regulated by the
pretreatment program through categorical pretreatment standards
Appendix C Industrial Categories Subject to National Categorical Pretreatment Standards
(previously titled "34 Industrial Categories")
The Appendix C published on January 21, 1981, listed 34 industrial categories
originally expected to be regulated by the pretreatment program through categorical
pretreatment standards. Appendix C was revised on June 4, 1986, to incorporate
changes to previous categorization, to delete categories that were exempted by
paragraph 8 of the NRDC vs. EPA Consent Decree, and to incorporate additional
categories for which standards are being developed or considered.
Appendix D Selected Industrial Subcategories Considered Dilute for Purposes of the Combined
Wastestream Formula (previously titled "Selected Industrial Subcategories Exempted
from Regulation Pursuant to Paragraph 8 of the NRDC v. Costle Consent Decree"
The Appendix D published on January 21, 1981, provided a list of industrial
Subcategories that had been exempted (pursuant to paragraph 8 of the NRDC vs.
EPA Consent Decree) from regulation by categorical pretreatment standards.
Appendix D was revised on October 9, 1986, to update the list of exempted industrial
categories and to correct previous errors by either adding or removing various
Subcategories or by changing the names of some categories or Subcategories. Each
of the Subcategories, as indicated by the revised Appendix D title, contains
wastestreams that are classified as dilute for purposes of applying categorical
pretreatment standards to other wastestreams and for using the combined
wastestream formula to adjust these standards.
Appendix E Sampling Procedures
This appendix provides a general description of composite and grab sampling
procedures.
Hazardous Waste Authorities
This appendix lists the EPA Regional and State Hazardous Waste Authority required
to receive notification of hazardous wastes discharged.
Appendix to
403.12(p)
Appendix G Regulated Pollutants in Part 503 Eligible for a Removal Credit
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Chapter Nine
Pretreatment
Table 9-2
Categorical Pretreatment Standards
Industrial Categories With Categorical Pretreatment
Standards in Effect
Effluent Guidelines Currently Under
Development*
N Aluminum Forming (Part 467)
E N Battery Manufacturing (Part 461)
E N Builder's Paper and Board Mills (Part 431)
E N Carbon Black Manufacturing (Part 458)
N Coil Coating (Part 465)
E N Copper Forming (Part 468)
E N Electrical and Electronic Components
E (Part 469)
Electroplating (Part 413)
E N Fertilizer Manufacturing (Part 418)
N Glass Manufacturing (Part 426)
N Grain Mills Manufacturing (Part 406)
N Ink Formulating (Part 447)
N Inorganic Chemicals (Part 415)
E N Iron and Steel Manufacturing (Part 420)
E N Leather Tanning and Finishing (Part 425)
E N Metal Finishing (Part 433)
E N Metal Molding and Casting (Part 464)
E N Nonferrous Metals Forming and Metal
E Powders (Part 471)
N Nonferrous Metals Manufacturing (Part 421)
E N Organic Chemicals, Plastics, and
E Synthetic Fibers (Part 414)
N Paint Formulating (Part 446)
N N Paving and Roofing Materials (Part 443)
E N Pesticide Chemicals (Part 455)
E N Petroleum Refining (Part 419)
E N Pharmaceutical Manufacturing (Part 439)
E N Porcelain Enameling (Part 466)
E N Pulp, Paper, and Paperboard (Part 430)
N Rubber Manufacturing (Part 428)
N Soap and Detergent Manufacturing
(Part 417)
E N Steam Electric Power Generating (Part 423)
E N Timber Products Processing (Part 429)
Pesticide Formulating, Packaging, and
Repackaging
Pulp, Paper, and Paperboard
Pharmaceutical Manufacturing
Metal Products and Machinery
(Phase I).
Landfills and Incinerators
Industrial Laundries
Transportation Equipment Cleaning
Two additional categories yet to
be specified.
Centralized Waste Treatment
Coastal Oil and Gas Extraction
Future Effluent Guidelines to Be Developed*
Metal Products and Machinery
(Phase II)
Categories Being Studied for Possible
Selection as One of the Two Additional
Categories*
Metal Finishing
Petroleum Refining
Iron and Steel Manufacturing
Inorganic Chemicals
Textile Mills
Steam Electric Power Generating
Pulp, Paper, and Paperboard (portion)
E = Standards in effect for existing sources.
N = Standards in effect for new sources.
*From May 18, 1994, Effluent Guideline Plan [304(m)J.
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Chapter Nine Pretreatment
*** NOTES ***
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9- PRETREATMENT
B. Pretreatment Compliance
Inspections (PCIs) and Audits
Scope of PCIs and Audits
The Pretreatment Compliance Inspection (PCI), the pretreatment program audit, and the
program performance report (submitted at least annually) have been developed as oversight
mechanisms for Approval Authorities. They provide an opportunity for EPA and State officials
to assess the Control Authority's pretreatment program. The PCI and the audit provide an
opportunity for EPA and State officials to conduct an onsite review of a Control Authority
pretreatment program.
The focus of the PCI is to evaluate Control Authority compliance monitoring and enforcement
activities. The PCI also is designed to determine whether any changes have been made to
the Control Authority program since the last PCI, audit, performance report (i.e., annual
report), or Control Authority program modification request approval. The role of a NPDES
inspector during a PCI is as a data gatherer to collect information on Control Authority
program implementation for further evaluation by compliance personnel.
The PCI may be conducted in conjunction with other NPDES inspections to conserve travel
resources and allow integration of information on the many facets of a POTW's operations.
PCIs are compatible with Compliance Evaluation Inspections (CEIs), Compliance Sampling
Inspections (CSIs), Performance Audit Inspections (PAIs), Diagnostic Inspections (DIs), and
other nonroutine inspections, such as Toxics Sampling Inspections, and Compliance
Biomonitoring Inspections. A PCI may also be combined with a site visit regarding sludge
compliance as discussed in Chapter Ten.
It should be noted that the POTW personnel involved in a CSI may be different from the ones
involved in a PCI. Also, PCIs and audits rely heavily on file and record reviews to evaluate
the Control Authority's pretreatment program. These records may have little bearing on a
technical inspection of the treatment facility. This aspect of a PCI should be addressed during
planning for the inspection. Inspectors responsible for performing PCIs must be familiar
enough with the goals of the program, the General Pretreatment Regulations, and EPA/State
policy and guidance to conduct the inspection in a manner that will obtain information to
detect noncompliance with pretreatment requirements.
Audits have been designed as a comprehensive review of all facets of the Control Authority
pretreatment program. The audit addresses all of the items covered in a PCI but in greater
detail. Consequently, the audit is more resource intensive than the PCI.
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Chapter Nine . Pretreatment
Procedures for conducting PCIs and audits are similar. In general, there are three major
components:
• Pre-visit preparation for the PCI or audit
- Coordination with the EPA Regional or State Pretreatment Coordinator
- Review of background information: approved program, Control Authority annual
reports (if available), NPDES permit compliance status, Control Authority fact sheet,
previous inspection reports, and program modification requests from the Control
Authority
- Notification of Control Authority-(if appropriate).
• Onsite
- Entry (presenting credentials)
- Opening conference with Control Authority officials
- Review of pretreatment files
- Industrial inspections (optional)
- Interview of officials using PCI or audit checklist
- Tour of POTW (optional)
- Closing conference.
• Follow-up
- Preparation of report
- Water Enforcement National Data Base (WENDB) data entry into PCS
- Reportable Noncompliance/Significant Noncompliance (RNC/SNC) determination
- Follow-up letter to the Control Authority
- Enforcement action (when necessary)
- NPDES permit or program modifications (when necessary).
If a PCI is conducted with an unannounced NPDES inspection, it also may be unannounced,
but the Control Authority officials should be notified of the PCI upon arrival of the inspection
team. At many POTWs, personnel responsible for implementing the program may not be the
same as those operating the treatment plant.
The protocol involved in the onsite portion of the inspection is comparable to that of other
NPDES inspections. One aspect of a PCI or an audit that differs from other NPDES
compliance inspections is inclusion of a tour of industrial facilities discharging to the POTW.
This aspect may be included as an optional component of both PCIs and audits to evaluate
the Control Authority's procedures for monitoring and inspecting industries. For more detailed
information on conducting PCIs and audits, refer to EPA's Guidance for Conducting a
Pretreatment Compliance Inspection (September 1991), and Control Authority Pretreatment
Audit Checklist and Instructions (May 1992).
Detailed checklists intended for use during PCIs and audits are provided in the PCI and audit
guidance manuals, respectively. The organization and focus of the detailed checklist are
discussed in the following section.
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Chapter Nine Pretreatment
PCI Checklist Components
The PCI checklist was developed to assist NPDES inspectors in conducting and documenting
the PCI. The checklist is organized into the following sections:
• Cover page—Provides space for Control Authority name, address, and representatives
present, as well as the date(s) of the inspection and inspectors' names, titles, and
telephone numbers.
• Section I: Industrial User File Evaluation—This section documents problems or
deficiencies noted during review of industrial user files. Generally, files are reviewed to
determine whether the Control Authority has notified the industrial user of applicable
categorization and requirements, issued an adequate control mechanism, properly
applied pretreatment standards, conducted sufficient compliance monitoring activities,
and taken appropriate enforcement actions for violations.
• Section II: Supplemental Data Review/Interview—This section is completed by
interviewing the appropriate Control Authority personnel and enables the inspector to
determine compliance with program requirements not easily determined by the file
review or to acquire additional information. This section contains questions on the
following six pretreatment program areas:
- Control Authority Pretreatment Program Modifications
- Industrial User Characterization
- Control Mechanism Evaluation
- Application of Pretreatment Standards and Requirements
- Compliance Monitoring
- Enforcement.
• Section III: Evaluation and Summary—This section consists of the same six
pretreatment program areas listed above and allows the inspector to summarize
deficiencies noted and any corresponding required and/or recommended corrective
actions.
• Attachment A: Pretreatment Program Status Update—This section provides an update
of the pretreatment program's status. It should be updated prior to the PCI, based on
information from the most recent PCI or audit and latest pretreatment program
performance report and should be revised based on information obtained during the
PCI, if necessary.
• Attachment B: Pretreatment Program Profile—This section provides information on the
Control Authority's approved pretreatment program, NPDES permit conditions, and
applicable pretreatment regulations.
• Attachment C: Worksheets
- WENDB Data Entry Worksheet—The WENDB data elements provide information to
be entered in the Pretreatment Permits and Enforcement Tracking System
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Chapter Nine Pretreatment
(PPETS). This management information system tracks the permit compliance and
enforcement status of approved pretreatment programs.
- Reportable Noncompliance (RNC) Worksheet—This worksheet evaluates whether
the Control Authority is in RNC for failure to implement its approved pretreatment
program.
- ID Site Visit Report—This report documents any industrial user site visits that were
conducted as part of the PCI.
- ID File Evaluation Worksheets—These optional worksheets assist the inspector in
documenting and quantifying the Control Authority's performance in applying
standards, compliance monitoring, and enforcement activities.
In addition to the completed checklist, other materials collected during the PCI may be
included in the final report as appendices, such as the following:
• Example of Control Authority control mechanism or enforcement actions
• Names of industries that were not sampled or inspected in the past year
• Control Authority's Enforcement Response Plan (ERP)
• Annual list of industrial users in significant noncompliance.
The PCI checklist can be found in EPA's Guidance for Conducting a Pretreatment Compliance
Inspection (September 1991). The manual goes through each checklist section individually
and explains the intent of the questions. As noted earlier, the manual provides more detailed
information concerning the procedures for conducting the PCI.
Summary of Audit Checklist Components
The audit checklist has been developed to assist with a detailed review of a POTW
pretreatment program, including pretreatment program modification, legal authority, industrial
user characterization, control mechanism evaluation, application of pretreatment standards
and requirements, compliance monitoring, enforcement, data management/public participation,
resources, and environmental effectiveness/pollution prevention. The audit checklist is divided
into the following sections:
• Cover page
• Section I: Industrial User File Evaluation
• Section II: Data Review/Interview/Industrial User Site Visits
• Section III: Findings
• Attachment A: Pretreatment Program Status Update
• Attachment B: Pretreatment Program Profile
• Attachment C: Worksheets
- Industrial User Site Visit Data Sheet
- WENDB Data Entry Worksheet
- RNC Worksheet.
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Chapter Nine Pretreatment
The sections of the audit checklist have been developed to collect more detailed information
than the PCI checklist and, as with the completed PCI checklist, also may be augmented by
additional audit data:
• NPDES pretreatment permit conditions
• Control Authority enforcement documents with pretreatment requirements (i.e.,
administrative order, consent decree)
• Locally developed discharge limitations as included in the approved program (or any
limits that have been changed by the Control Authority)
• Copy of sewer use ordinance if different from that in the approved program
• Control Authority sampling and inspection schedule for regulated industries
• List of industries not sampled or inspected in the past year
• Control Authority chain-of-custody form
• List of noncompliant industries and history of enforcement actions taken
• Annual list of industrial users in significant noncompliance.
The audit checklist is incorporated as part of the Control Authority Pretreatment Audit
Checklist and Instructions (May 1992). The manual provides specific guidance on conducting
an audit and using the checklist.
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Chapter Nine Pretreatment
NOTES ***
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9. PRETREATMENT
C. References
EPA's Guidance for Conducting a Pretreatment Compliance Inspection (September 1991)
contains a comprehensive list of reference materials (publications and memorandums)
available from U.S. EPA or the Pretreatment Coordinator in your Region. References that
have been published since the publication of the Pretreatment Guidance are listed
below.
Checklists for conducting pretreatment compliance inspections and audits are provided in
EPA's Guidance for Conducting a Pretreatment Compliance Inspection (September 1991) and
Control Authority Pretreatment Audit Checklist and Instructions (May 1992). The checklist
provides a list of questions that should be considered during an audit or PCI, and is available
from EPA Regional offices. The Regional or State Pretreatment Coordinator should be
contacted before a PCI or an audit is done.
References
Memoranda
Determining Industrial User Significant Noncompliance (January 17, 1992).
Determining Industrial User Compliance Using Split Samples (January 21, 1992).
Statistical Assessment of National Significant Industrial User Noncompliance (July 23, 1992).
Use of Grab Samples to Detect Violations of Pretreatment Standards (October 1, 1992).
Using Split Samples to Determine Industrial User Noncompliance (April 12, 1993).
EPA Guidance
U.S. Environmental Protection Agency. May 1991. Supplemental Manual on the
Development and Implementation of Local Discharge Limitations Under the Pretreatment
Program.
U.S. Environmental Protection Agency. June 1992. Guidance to Protect POTW Workers from
Fume Toxic and Reactive Gasses and Vapors. EPA 812-B-92-001.
U.S. Environmental Protection Agency. April 1994. Industrial User Inspection and Sampling
Manual for POTWs. EPA 831 -B-94-001.
U.S. Environmental Protection Agency. June 1994. Multijurisdictional Pretreatment Programs
Guidance Manual. EPA 833-94-005.
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Chapter Nine Pretreatment
NOTES ***
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10. SEWAGE SLUDGE
Contents Page
A. Review of the Sewage Sludge Regulations
Land Application Requirements 10-2
Surface Disposal Requirements 10-5
Incineration Requirements 10-6
B, Sludge Inspection Procedures
Scope of Inspection Activities 10-9
Inspection Preparation 10-10
Records Review 10-11
Facility Site Review 10-14
Sampling and Laboratory Quality Assurance 10-16
C. References
References 10-31
List of Tables
10-1 Records Relevant for Sludge Operations 10-20
10-2 Operating Records for Specific Unit Processes 10-21
10-3 Sludge Sampling Points 10-23
10-4 Recordkeeping Requirements for Class A Pathogen Reduction
Alternatives 10-24
10-5 Recordkeeping Requirements for Class B Pathogen Reduction
Alternatives 10-26
10-6 Recordkeeping Requirements for Vector Attraction Reduction
Sludge Processing Options 10-27
10-7 Sludge Handling Process Evaluation 10-28
10-8 Pollutants Monitored for Land Application, Surface Disposal,
and Incineration 10-30
10-i
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Chapter Ten Contents
List of Figures
10-1 Sludge Quality Requirements for Land Application Uses 10-7
10-2 Sludge Quality Requirements for Surface Disposal 10-8
Associated Appendices
I Sludge Inspection Checklists
J Approved Methods for the Analysis of Sewage Sludge (40 CFR Part 503)
10-ii
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10. SEWAGE SLUDGE
A. Review of the Sewage Sludge
Regulations
Section 405 of the Clean Water Act (CWA) mandated the development of a Federal sludge
management program. On February 19, 1993, Environmental Protection Agency (EPA)
promulgated technical standards for the use or disposal of sewage sludge [see 40 Code of
Federal Regulations (CFR) Part 503, 58 Federal Regulation (FR) 9248]. These regulations
contain technical standards for three sewage sludge use or disposal practices: land
application, surface disposal, and incineration. The National Pollutant Discharge Elimination
System (NPDES) regulations had previously been changed in preparation for the issuance of
the final technical standards. As NPDES permits are being reissued, they are being written to
include sludge use or disposal requirements. However, the Federal 503 sludge regulations
are constructed so that they apply to and are enforceable against a facility engaged in a
regulated sludge use or disposal practice, regardless of whether that facility's NPDES permit
contains sludge use or disposal conditions. Thus, the NPDES permit is not a shield in the
case of compliance with sludge requirements. This means that as of February 19, 1994,
inspectors will be expected to identify and issue notices for those violations of Part 503
requirements, whether or not specifically included in a facility's NPDES permit.
The Federal sludge management program currently regulates the use and disposal of sewage
sludge, which is the residual generated from the treatment of domestic sewage. Facilities,
such as Publicly Owned Treatment Works (POTWs), which are subject to NPDES permit
conditions for aqueous discharges to surface waters are now, as generators and preparers of
sewage sludge, subject to the 503 regulations. In addition, the sludge program includes other
facilities that have not been a part of the NPDES program because they were not point
sources of discharge to waters of the United States. Examples of facilities that are now
regulated and that may eventually receive permits for the use and disposal of sewage sludge
include sewage sludge incinerators, composting facilities, and sewage sludge surface disposal
sites.
While EPA was in the process of finalizing more comprehensive regulations to address the
use or disposal of sewage sludge, there were existing Federal regulations that applied to the
land application and landfilling of sludge. These regulations, issued as interim final criteria in
40 CFR Part 257, were promulgated jointly under the authority of the CWA and the Resource
Conservation and Recovery Act (RCRA) in 1979. They have since been replaced for the most
part by regulations promulgated in 40 CFR Part 258 for disposal of sewage sludge in
Municipal Solid Waste Landfills (MSWLFs) and 40 CFR Part 503 for sewage sludge use or
disposal by land application, surface disposal, or incineration. The application of industrial
sludge to the land continues to be regulated by 40 CFR Part 257. In addition, the Clean Air
Act (CAA) regulates the operations and air emissions of sewage sludge incinerators under 40
CFR Parts 60 and 61. The relevant requirements in 40 CFR Part 258 and 40 CFR Part 60
and 61 are described below.
10-1
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Chapter Ten Sewage Sludge
40 CFR Part 258—On October 9, 1991, EPA promulgated regulations under Part
258 that established criteria for MSWLFs and standards for the co-disposal of
sewage sludge with municipal solid waste. Part 503 requires that sewage sludge be
sent to a MSWLF to comply with the appropriate Part 258 requirements. Because
the material that is disposed of in MSWLFs is very diverse (e.g., household garbage,
sanitary septic tank waste, commercial solid waste and sewage sludge), the
approach to regulating solid waste is different. Instead of regulating pollutants in the
solid waste, Part 258 imposes design, operation, and maintenance requirements on
the final disposal site. Although pollutant limits are not imposed, sludge to be
disposed of must be nonhazardous, as demonstrated by using the Toxicity
Characteristic Leaching Procedure (TCLP) and passing a paint filter test.
40 CFR Part 60, Subpart O—Emission standards for particulates and opacity and
operational standards are specified for new source sewage sludge incinerators. New
source incinerators are those constructed after June 11, 1973. If mixed municipal waste
is being incinerated, then Subpart Ea—Standards of Performance for Municipal Waste
Combustors—apply.
40 CFR Part 61—Standards were promulgated under authority of the CAA that limit
the emission of beryllium and mercury from sewage sludge incinerators. The Part
503 sludge regulations require compliance with the Part 61 beryllium and mercury
emission standards.
In general, the Part 503 regulations are structured to apply the following types of requirements
to the three sewage sludge use or disposal practices:
• Pollutant limits (10 pollutants regulated under land application, 3 under surface
disposal, and 7 under incineration)
• Pathogen and vector attraction reduction requirements
• Management practices for siting and operation of sludge use or disposal activities
• Minimum monitoring requirements
• Specific recordkeeping and reporting requirements.
A brief explanation of the requirements that apply to each sewage sludge use or disposal
practice is provided below.
Land Application Requirements
Pollutant Limits
Four types of limits have been established that regulate 10 pollutants. Figure 10-1 illustrates
which limits apply, based on the final sludge use.
10-2
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Chapter Ten Sewage Sludge
• Ceiling Concentration Limits—These limits are expressed as milligram of pollutant per
kilogram of sludge on a dry weight basis. They apply to all sewage sludge land
applied.
• Cumulative Pollutant Loading Rates (CPLRs)—These limits are expressed as the total
amount of pollutant (kilograms) that can be applied to an area (hectare) of land. When
this loading rate is reached, no further sludge can be applied to the site. These rates
apply to bulk sewage sludge.
• Pollutant Concentration Limits—These limits are expressed as the monthly average
concentration of pollutant milligram per kilogram of sludge on a dry weight basis. They
apply to sewage sludge sold or given away in a bag or other container and as an
alternative limit to CPLRs for bulk sewage sludge.
• Annual Pollutant Loading Rates—These limits are expressed as the amount of
pollutant (kilogram) that can be applied in a 365-day period on an area (hectare) of
land. This loading rate limits the amount of sludge on a dry weight basis that can be
applied each year. These rates apply as an alternative limit for sewage sludge sold or
given away in a bag or other container if it cannot meet the monthly average pollutant
concentration limits.
In summary, bulk sewage sludge is subject to two sets of limits:
• Ceiling Concentration Limits and
• Pollutant Concentration Limits or Cumulative Pollutant Loading Rates, depending upon
sludge quality.
Sewage sludge sold or given away in a bag or other container is subject to two sets of limits:
• Ceiling Concentration Limits and
• Pollutant Concentration Limits or Annual Pollutant Loading Rates, depending upon
sludge quality.
Management Practices
The five management practices are intended to supplement the pollutant limits and provide
additional protection to endangered species or their habitat, surface water, wetlands, ground
water, and human exposure to the sludge. Four are applicable to bulk sludge; one is
applicable to bagged or containerized sludge.
Operational Standards: Pathogen and Vector Attraction Reduction Requirements
There are two categories of pathogen reduction requirements: Class A and Class B (with
associated site restrictions on the use of Class B sludge).
10-3
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Chapter Ten Sewage Sludge
• Class A requirements result in essentially pathogen-free sludge that may be used
immediately with unrestricted public access.
• Class B requirements significantly reduce (but do not eliminate) the pathogen count in
the sludge and require a waiting period before the land on which the sludge was
applied may be used for certain activities.
Sludge that is sold or given away in a bag or other container must meet Class A
requirements. Bulk sludge that goes to lawn or home garden use must also meet Class A
requirements. Bulk sewage sludge applied elsewhere (i.e., agricultural land, forest, public
contact sites, or reclamation sites) must meet either Class A or Class B requirements.
Under Part 503, six treatment alternatives are available for achieving Class A sludge. Three
treatment alternatives (with specific site restrictions for use of the treated sludge) are provided
for achieving Class B sludge.
The Part 257 interim regulation established specific sludge treatment processes and their
operating parameters to be used to achieve the appropriate level of pathogen reduction. EPA
retained substantially the same pathogen reduction treatment processes from Part 257 in the
Part 503 regulations. Therefore, among the alternatives to achieve Class B sludge is
treatment using one of the Processes to Significantly Reduce Pathogens (PSRP). Similarly,
Class A sludge may be achieved by using one of the Processes to Further Reduce Pathogens
(PFRP).
Land applied sludge is subject under the Part 503 regulations to vector attraction reduction
requirements to reduce the characteristics of the sludge that attract disease vectors (i.e.,
insects and mammals that are capable of transporting infectious agents, ultimately to
humans). Part 503 requires compliance with one of eight vector attraction reduction treatment
alternatives if the sludge will be sold or given away in a bag or other container. Bulk sewage
sludge applied to lawns or home gardens must also meet one of eight vector attraction
reduction treatment alternatives. Bulk sewage sludge applied elsewhere must meet one of 10
treatment alternatives.
Monitoring. Recordkeeping, and Reporting Requirements
Minimum self-monitoring frequencies, which range from once per year to monthly, are
specified in Part 503 based on the volume of sludge to be applied. More (or less) stringent
monitoring frequencies may also be imposed through a permit mechanism.
Part 503 recordkeeping requirements differ depending on the type of pollutant limits applied.
Recordkeeping requirements, including the certification statements specified in Part 503, are
imposed on generators/preparers, while other specific recordkeeping requirements are
imposed on appliers. Most of the specific information is required to be retained for 5 years,
except that some information for sludge regulated by cumulative pollutant loading rates must
be retained indefinitely.
Only a subset of the facilities required to maintain records is required to report under the Part
503 regulations. Those facilities that must report at least once per year are listed below.
10-4
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Chapter Ten Sewage Sludge
Class I sludge management facilities
POTWs with a design capacity equal to or greater than 1 Million Gallons per Day
(MGD)
POTWs serving a population of 10,000 or more.
Surface Disposal Requirements
Pollutant Limits
Three pollutants are regulated. Limits apply to sewage sludge that is placed on or in a
surface disposal site that does not have a liner and leachate collection system. There are no
limits on sewage sludge placed in sewage sludge units equipped with a liner and leachate
collection system. The distance between the active sewage sludge unit and the site property
line/boundary determine the specific pollutant limits that apply; the closer the distance to the
boundary, the more stringent the limits (see Figure 10-2). An owner/operator can request site-
specific pollutant limits; these limits would be established by the permitting authority through a
permit.
Management Practices
A total of 14 management practice requirements are established in Part 503. Many are one-
time surface disposal site location restrictions. Others address operational activities (e.g.,
leachate and runoff collection systems, methane gas monitoring) and post-closure activities.
Operational Standards
Sewage sludge must meet one of the Class A or Class B pathogen reduction treatment
alternatives, but need not meet any of the Class B site restrictions (since they are only
applicable to land applied sewage sludge). Surface disposed sludge must also meet one of
eleven vector attraction reduction alternatives. However, if the sewage sludge is covered at
the end of each day (one of the vector attraction reduction alternatives), the sludge is deemed
to have met pathogen reduction requirements.
Monitoring, Recordkeepinq, and Reporting Requirements
Monitoring and recordkeeping requirements, including the certification statements specified in
Part 503, are imposed on the sludge generator or final preparer and/or the owner/operator of
the surface disposal site. Minimum monitoring frequencies are established based on the
volume of sludge disposed of. All records are required to be maintained for 5 years. The
same classes of facilities identified under the land application section are required to report at
least once per year.
10-5
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Chapter Ten Sewage Sludge
Incineration Requirements
Pollutant Limits
A total of seven pollutants are regulated. Limits for five metals are calculated by the
permitting authority based on site-specific factors using the equations specified in the Part 503
regulations. Limits for the other two pollutants (mercury and beryllium) are derived from air
emission standards promulgated under 40 CFR Part 61. These limits appear in the permit
issued to the owner/operator of the sewage sludge incinerator.
Operational Standards
The regulations establish a monthly standard on the total hydrocarbons concentration in the
exit gases of an incinerator to protect from excessive emissions of organic pollutants.
Management Practices
Seven management practices ensure that certain instruments are correctly installed,
calibrated, operated, and maintained; that incinerator maximum combustion temperature and
air pollution control equipment operating standards are established; and that endangered
species and their habitats are protected. The specific management practice requirements
should be established by the permitting authority based on site-specific factors and should
appear in the incinerator's permit.
Monitoring. Recordkeeping and Reporting Requirements
Monitoring Requirements. In general, monitoring requirements for sewage sludge to be
incinerated are imposed on the owner/operator of the incinerator. Part 503 requires
monitoring (a) of sewage sludge for pollutant (i.e., metals) concentrations; (b) of incinerator
stack exit gases for total hydrocarbon or, alternatively, carbon monoxide (CO), oxygen
concentrations, and moisture content; and (c) of incinerator combustion temperatures and air
pollution control equipment operating parameters. Monitoring requirements to demonstrate
compliance with Part 61 beryllium and mercury standards are also likely to be imposed on
owners/operators of sewage sludge incinerators.
Recordkeeping Requirements. Records required to be maintained by owners/operators of
incinerators are specified both in Part 503 and site-specific conditions in the NPDES or sludge
permit.
Reporting Requirements. The same classes of facilities identified under the land application
section are required to report at least once per year. In this case, reporting requirements are
imposed on owners and operators of sewage sludge incinerators.
10-6
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Chapter Ten
Sewage Sludge
Figure 10-1
Sludge Quality Requirements for Land Application Uses
• Final Use or • Pathogen • ^ H
S!!1 • ^S. • Reduction H^H
Pollutant Limits
^^IIIHII^H IIIIHIHIH ^^^2Q£Qj^^| „...„' . i
Limits — Table 1 of §503.13 '
Pollutant
LAND APPLICATION
Arsenic
Bulk sewage Cadmium
.inrfdnnniirrt to. pi mil to. AnV of vector ^ rhmmiiim
to: options 1-8 Copper Lead
• Lawn or home garden Molybdenum
Nickel
Selenium
Zinc
m*mm*mmmm.
Maximum I
(mg/kg) 1
5
7585 ••
3000 |
4300 |
840 1
5775 8
420 *
100 13
7500 j
Limits — Table 3 of §503.13
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Zinc
Monthly Avg.
(mg/kg)
41 39
1200
1500
300
17
420
36
2800
* ' -- •'•• - <^~ *
Sell or give _ „, „ _ Any of vector ^ Ceiling concentration |
away in bag or to- Class A »- options 1-8 ^~ limits in Table 1 |
other container " above )
1
ifud^m^l to. CUr,Ac,,n to. Al>v of vector ^ Ceiling concentration }
iludgc applied to- CldssAo!B to- options 1-10 *^ limits in
to: ' abo
• Forest land
• Public contact site
• Reclamation site
Table 1 i-
i
Pollution C
Limits in Tab
Annual Poll
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Zinc
oncentration
le 3 Above OR
utant Loading
e 4 of §503.13
APLR Kg/Ha/
365 day penod
2.0
1.9
150.0
75.0
15.0
21.85
5.0
140.0
Pollution C
Limits in Tab
Cumulative Po
Rates — Tablt
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Zinc
oncentration
e 3 Above OR
llutant Loading
2 of §503.13
CPLR Kg/Ha
41 39
3000
1500
300
17
420
100
2800
1
:
'i
1
1
i
-i
1
461B-02a
10-7
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Chapter Ten
Sewage Sludge
Figure 10-2
Sludge Quality Requirements for Surface Disposal
SURFACE DISPOSAL
•Unlined „. .
sewage sludge *»
unit '
or B or ^ Any of vector
cover options 1-11
*Site-spectfic limits may be
approved by the permitting
authority, if requested
Unit Boundary to
Property Line
Distance in Meters
0 to < 25 25 to
<50
50 to < 75
75to< 100
100 to < 125
125 to < 150
150 and greater
Pollutant Concentrations*
Arsenic
mg/kg
30
34
39
46
53
62
73
Chromium
mg/kg
200
220
260
300
360
450
600
Nickel
mg/kg
210
240
270
320
390
420
420
Sewage sludge
unit with
liner/leachate
collection
^-
Class A or B or
daily cover
^-
Any of vector
options 1-11
No pollutant limits
461B-02b
10-8
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10. SEWAGE SLUDGE
B. Sludge Inspection Procedures
Scope of Inspection Activities
Inspectors should verify compliance with the following general activities:
• Sludge monitoring, recordkeeping, and reporting
• Sludge treatment operations
• Sludge sampling and laboratory Quality Assurance (QA).
EPA intends for the evaluation of sludge management activities to be incorporated into the
existing inspection structure so that inspection resources can be used most efficiently. The
inspector can identify and investigate problems that might contribute to noncompliance with
sludge requirements during any inspection site visit. The Pretreatment Compliance Inspection
(PCI), the Compliance Evaluation Inspection (CEI), and the Performance Audit Inspection
(PAI) are the most likely vehicles for evaluating compliance with sludge requirements.
However, the NPDES inspector may use any of the following existing NPDES inspections
when evaluating sludge requirements:
• CSI—The Compliance Sampling Inspection (CSI) may be used if the inspector decides
that sludge sampling is necessary to determine compliance with applicable
requirements.
• CEI—The inspector has historically looked at sludge treatment as part of the CEI
because of its effect on wastewater treatment. This evaluation of sludge treatment
should be expanded to include a review of sludge monitoring, reporting, and record-
keeping, and a more comprehensive evaluation of the Operation and Maintenance
(O&M) of sludge treatment processes, to evaluate compliance with sludge permit
requirements.
• PAI—The PAI may be expanded to evaluate compliance with sludge monitoring
requirements, and evaluate the permittee's sludge sampling and analytical procedures.
NPDES inspectors are not required to conduct an in-depth compliance assessment of sludge
final use and disposal practices when such practices occur away from the treatment plant. In
situations where final use and disposal requirements have been established in the facility's
NPDES permit (e.g., management practices such as 10-meter buffer zones between the
sludge application site and surface waters) and the activity is offsite, the inspector should
verify compliance with those requirements through a records review at the facility. As part of
a sampling inspection, the inspector may need to sample the sludge to determine compliance
with pollutant limits.
10-9
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Chapter Ten Sewage Sludge
EPA intends to focus sludge inspection activities on those aspects of sludge management that
can easily be evaluated during an existing NPDES compliance or pretreatment inspection.
Inspectors will rely on an evaluation of sludge treatment operations, the observation of onsite
sludge storage and disposal activities, and the review of sludge monitoring and disposal
records to identify actual and potential noncompliance with sludge requirements. Inspectors
should document compliance or noncompliance with sludge final use or disposal requirements
in accordance with standard NPDES compliance inspection procedures.
An inspection checklist is an essential field tool for documenting that all necessary information
has been collected. Inspection checklists are included in Appendix I of this manual. These
checklists are based on the checklists in EPA's Guidance for NPDES Compliance Inspector:
Evaluation of Sludge Treatment Processes (USEPA November, 1991) and Guidance for
NPDES Compliance Inspector: Verifying Compliance with Sludge Requirements (USEPA
November, 1991), as modified by EPA Region 8. The checklists should be used in
conjunction with the checklist questions found in the 1991 guidance manuals. However,
sludge permits may contain additional sludge permit conditions, based on case-by-case
considerations, that are not included on the checklist. The inspector should identify additional
permit requirements and verify compliance with these conditions as well. To accomplish this,
it is recommended that the inspector expand the checklist, if necessary, to ensure that it is
specific to the NPDES permit and the sludge final use or disposal activity. The inspector
should complete the checklist and should incorporate his/her findings and conclusions in the
final inspection report prepared for the facility.
The NPDES compliance inspector should consult EPA's 1991 Guidance for NPDES
Compliance Inspector: Evaluation of Sludge Treatment Processes when preparing to conduct
a sludge inspection. This technical reference presents a detailed examination of sludge unit
processes and also contains extensive technical checklists that summarize the most critical
elements of sludge thickening, stabilization, conditioning, dewatering, and disinfection. A
technical understanding of the proper design and operation of the sludge treatment processes
is essential for conducting thorough and informed sludge inspections.
Inspection Preparation
On preparing for the inspection, the inspector should:
• Review the NPDES Permit (or the facility's sludge permit, if applicable). When
reviewing the NPDES permit file in preparation for the inspection, identify:
- Permit conditions applicable to sludge including treatment; general requirements;
management practices; and monitoring, reporting, and recordkeeping requirements.
- Any additional requirements in the NPDES permit that may reflect State regulations.
Additionally, the NPDES permit may incorporate a separate State permit by
reference, in which case the State permit is also enforceable under the Federal CWA.
• Review sludge self-monitoring data.
• Become familiar with the sludge disposal practices used.
10-10
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Chapter Ten Sewage Sludge
Review appropriate Federal regulations (i.e., 40 CFR Part 503 Regulations, or Part
258 if sludge is disposed of in a municipal solid waste landfill, and any other applicable
State or local regulations).
Review relevant guidance for background information and implementation procedures
(e.g., guidelines on calculating agronomic rate, EPA's Process Design Manuals for
Land Application of Municipal Sewage Sludge and Municipal Sludge Landfills, Control
of Pathogens in Municipal Sewage Sludge).
Verify that records kept by the permittee facilitate evaluation of compliance with sludge
requirements.
Records Review
The Part 503 sludge regulations contain recordkeeping and reporting requirements. The
facility's NPDES or sludge permit may have additional recordkeeping or reporting
requirements. An evaluation of the sludge records and reports found at the facility should be
conducted to determine compliance with these recordkeeping and reporting requirements.
The procedures listed below should be used for these routine inspections. If suspected
violations are uncovered during the routine evaluation, a more intensive investigation should
be conducted.
In the records review process, the evaluation of compliance with sludge recordkeeping
requirements should consider the following:
• Is all required information available for review?
• Are all regulated pollutants and sludge use and disposal practices addressed?
• Is all sludge information current?
• Are sludge records maintained for at least 5 years (commencing July 20, 1993)?
• Does the information contained in sludge records support the data submitted to the
permitting authority?
• Do the records indicate areas needing further investigation?
The inspector should also identify whether violations of sludge-related permit requirements
(e.g., concentration limits and/or management practices) have been reported, as required by
the permit. Finally, the inspector should verify that the permittee has notified EPA of any
changes to sludge use or disposal practices.
Evaluation Procedures
The inspector should first review the permit and fact sheet and list all sludge recordkeeping
requirements. Table 10-1 is a list of records that may be relevant for sludge. This list is
10-11
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Chapter Ten Sewage Sludge
supplemented by Table 10-2, which describes records relevant to the operation of specific
sludge treatment unit processes. Throughout the inspection, the facility's operations should
be compared with the permit conditions to verify that required permit activities for sludge are
correct, current, and complete.
An evaluation of sludge self-monitoring records and/or procedures involves the same elements
as an evaluation of their wastewater monitoring data; however, there are some special
considerations inherent in sludge sampling. In evaluating the permittee's records, inspectors
should look for documentation regarding:
• Regulated Pollutants—As identified in the NPDES permit or applicable Federal or State
regulations.
• Monitoring Frequency—As identified in the NPDES permit or applicable Federal or
State regulations. Note that Part 503 establishes minimum monitoring frequencies
based on the quantity of sewage sludge used or disposed of.
• Sample Location—The appropriate sampling point is the last treatment process the
sludge goes through before leaving the treatment plant for use or disposal. For
example, if a composted sludge is land applied, the compost pile should be sampled.
If digested sludge is land applied, the sludge should be sampled as it is transferred
from the digester to the truck prior to being hauled off site. Table 10-3 identifies
sludge sampling points appropriate for the various types of treated sludge.
• Sample Types—Grabs or composites may be appropriate depending on the situation,
but note that a grab sample from a lagoon, drying bed, compost pile, or truck must
consist of numerous samples collected from various places in the lagoon, bed, pile, or
truck and must be combined to make a representative sample.
• Sample Volume—If evaluating the sample collection process or taking samples, be
sure that the container is not filled completely. Some space should be left to allow for
expansion of the sample due to gas production. Refer to Appendix J for specific
sample volumes.
• Sample Containers—Sample containers are generally the same types as those used
for collection of wastewater samples, except that sludge sampling containers should be
wide mouth bottles. Refer to Appendix J for a description of the appropriate container
material.
• EPA Sample Identification Methods—Same as for wastewater sampling.
• Preservation and Holding Times—The primary difference in sludge preservation is that
samples should not be chemically preserved in the field because the sludge matrix
makes it difficult to thoroughly mix the preservative into the sample. However,
samples should be iced. Refer to Appendix J.
• Chain-of-custody—Same as for wastewater sampling.
• Quality Control—Same as for wastewater sampling.
10-12
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Chapter Ten Sewage Sludge
• Analytical procedures used by lab—The analytical methods used for sludge are
different from those used for wastewater. Approved analytical methods are listed in
Part 503 (40 CFR 503.8). For example, Part 503 requires that analyses for inorganic
pollutants use the procedures in Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods, EPA publication SW-846. The inspector should note the
information recorded regarding sample handling and analysis at the laboratory and
verify that it is correct. If evaluating the laboratory, the procedures are the same as
those followed in a PAI. The inspector should look at:
- Analytical procedures
- Laboratory services
- Instruments and equipment
-- Calibration
-- Maintenance
- Supplies
- Quality Assurance/Quality Control (QA/QC)
-- Precision and accuracy of measurement process
-- Data handling and reporting
-- Records retention
-- Personnel qualifications.
• Analytical Results—Verify that results documented in the files are consistent with those
reported.
The inspector should verify that reporting requirements are fulfilled according to the permit and
applicable regulations. The NPDES permit may or may not have specific reporting
requirements; however, the Part 503 sludge standards have specific reporting requirements
that apply regardless of whether they appear in the NPDES permit. The May 1989 revisions
to the NPDES regulations established required permit conditions regarding notification of
change and at least annual reporting of sludge monitoring results. As NPDES permits are
reissued, they will contain, at a minimum, these standard conditions as well as conditions
specified in Part 503. Based on the applicable requirements, the inspector should verify that:
• Reports contain all required information
• Reports are submitted at the required frequency
• Data are reported in Discharge Monitoring Report (DMR) or other approved form.
Inspectors should review unit operation records to verify compliance with pathogen and vector
attraction reduction requirements. Tables 10-4, 10-5, and 10-6 list the records and operating
requirements for the Part 503 Class A pathogen reduction alternatives, the Class B pathogen
reduction alternatives, and the vector attraction reduction options, respectively. Inspectors are
not expected to review each monitoring record, but rather to verify that records are being
maintained and are available for review. If a permittee has problems meeting either its
pathogen or vector attraction reduction requirements (e.g., fecal coliform or percent volatile
solids reduction), the inspector should review treatment operating records to identify potential
noncompliance with the particular operating requirements specified in Part 503 for the
particular pathogen and vector reduction process employed by the permittee. For example,
an inspector might check a treatment facility's pH or temperature records to determine
10-13
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Chapter Ten Sewage Sludge
whether the sludge has been maintained at the appropriate pH or temperature for the required
duration during treatment.
The inspector should verify that records are available for all disposal practices:
• Volume of sludge disposed of
• Sludge quality data
• Specific records appropriate for demonstrating compliance with the general
requirements, management practices, and operational standards.
Verify whether records are maintained in accordance with permit requirements. The May
1989 NPDES regulatory revisions created a mandatory permit condition requiring that sludge
records be kept for 5 years. However, many NPDES permits do not yet include this
requirement. The Part 503 regulations establish specific recordkeeping requirements for each
party involved in the sewage sludge use or disposal process.
Facility Site Review
Inspection of Solids Handling Unit Processes
To evaluate compliance with applicable sludge requirements, the inspector should fully
understand the sludge treatment processes used at the facility and how each process fits into
the overall treatment scheme. Sludge processing arguably poses the greatest challenges in
wastewater treatment from the standpoints of design, operation, and maintenance. Typically,
solids handling accounts for between 30 and 40 percent of the capital costs, 50 percent of the
operating costs, and 90 percent of the operational problems at sewage treatment plants.
These problems can not only prevent compliance with applicable Federal or State sludge
disposal regulations, but can also contribute to a treatment plant's noncompliance with its
NPDES permit effluent limits.
When conducting the walk-through visual inspection of the facility, the inspector should be
aware of, and look for, physical conditions that are indicative of potential or existing problems.
Some of the more common indicators of potential problems are listed in Table 10-7. The
presence of these conditions may warrant a more in-depth inspection of the sludge treatment
processes. A checklist is provided in Appendix I to assist the inspector during the facility site
review. The questions on this checklist are sludge-specific and should be asked in conjunction
with the Facility Site Review checklist. In addition, many of the questions in the NPDES
checklist relate to the overall operation of the facility and, therefore, can also be applied to
sludge evaluations (e.g., treatment units properly operated and maintained). The inspector
should look for conditions that indicate potential or existing problems. If the inspector finds
conditions that are a potential problem, this may trigger a more detailed evaluation. EPA has
developed guidance and checklists for conducting in-depth evaluations of each of the most
common sludge treatment unit processes, Guidance for NPDES Compliance Inspectors:
Evaluating Sludge Treatment Processes, November 1991.
The inspector should determine whether the facility is operating its sludge treatment and
disposal processes in a manner consistent with the requirements established in its NPDES
permit. If the inspector discovers conditions at the facility that threaten public health or the
10-14
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Chapter Ten Sewage Sludge
environment (e.g., contaminating ground water or surface water, exposing the public to
pathogens or disease vectors, or compromising public safety), the inspector should inform the
enforcement staff so that appropriate action can be taken. If knowing endangerment is
discovered, the criminal investigations unit should be informed.
Many large-scale operations are conducted outside, such as sludge drying, composting,
temporary and long-term storage, and loading and hauling. Inspectors should note these
outside operations' exposure to rainfall and runoff collection and treatment methods. If storm
water collection devices have been constructed, the inspector should evaluate the
performance and maintenance of these devices as well as their design capacity (e.g., the 10-
year 24-hour storm event or the 25-year 24-hour storm event). Visual observations can detect
obvious problems that may contribute to the contamination of surface water or ground water
such as erosion, breaches of dikes or berms, or cracks in the concrete or asphalt. The
inspector should inquire as to whether the capacity of the collection devices has ever been
exceeded during any storm event.
The sludge loading area should be inspected to determine how the sludge is being hauled or
transported. The inspector should note the size of the truckloads and the number of
truckloads hauled over a 1-day period (or another time period). These figures are useful to
the inspector in verifying the permittee's records and reports on the volume of sludge
generated and disposed of.
Sludge Storage
The inspector should also verify that the permittee has adequate storage capacity for its
sludge in the event that its preferred disposal method is interrupted for any reason (e.g.,
noncompliance with cumulative loading rates on the land application site). There are no
Federal requirements specifying a minimal storage capacity; the appropriate capacity will vary
depending on the amount of sludge generated and the facility's use or disposal option(s).
Storage capacity should address normal, routine storage prior to disposal and should
anticipate emergency conditions, such as:
• Equipment malfunction
• Inclement weather
• Unanticipated loss of disposal site.
- Farmer decides to discontinue use of sewage sludge
- Landfill violates requirements and may no longer accept sludge or is required to
close.
Some States have developed storage capacity requirements. If the permittee cannot dispose
of its sludge in the preferred manner, it should have either adequate storage capacity for its
sludge or clearly established plans for alternative methods of disposal.
10-15
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Chapter Ten • Sewage Sludge
Sampling and Laboratory Quality Assurance
The sludge inspection should evaluate the nature, scope, and adequacy of sludge sampling
and analysis conducted by the permittee. The most likely, existing inspection vehicle for
conducting this evaluation is the PAI, since it involves a detailed assessment of the
permittee's self-monitoring activities, including sample collection and laboratory analysis. The
findings of the sampling and laboratory QA review should be summarized and included in the
final inspection report for the facility.
Sampling Procedures and Techniques
The inspector's evaluation of the permittee's sludge sampling procedures will address similar
criteria as those evaluated in the context of wastewater sampling. The sampling procedure
elements that should be evaluated during the inspection include:
• Sample collection techniques
- Selection of representative sampling sites
- Sample types
- Sample volume
- Sample containers.
• EPA sample identification methods.
• Sample preservation and holding time.
• Chain-of-custody and shipment of samples.
• Quality Control (QC)
- Duplicates
- Blanks.
• Data handling and reporting.
A detailed discussion on evaluating these elements can be found in Chapter 5. While many
of these elements are evaluated using the same criteria, regardless of the media being
sampled, sludge sample collection techniques and sample preservation are different. The
inspector should review EPA's sewage sludge sampling video and refer to EPA's 1989 POTW
Sludge Sampling and Analysis Guidance Manual for detailed information regarding sludge
sampling procedures. Table 10-3 of this document summarizes appropriate sample locations.
Appendix J lists sample containers, preservation techniques, and holding times as a quick
reference for the inspector. In addition to these references, a few special sludge sampling
considerations are described below.
• Equipment. The equipment used to collect sludge samples is different from that used to
collect wastewater samples. The automatic composite samplers used to collect
wastewater cannot be used to collect sludge samples because the high solids content of
the sludge fouls the tubing. The type of equipment used to collect samples of soil or
other solid waste material is more appropriate for the collection of sludge samples.
Stainless steel buckets, trowels, and augers are typically used to collect solid sludge
10-16
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Chapter Ten Sewage Sludge
cake. Graduated glass or plastic pitchers or cylinders, or plastic or stainless steel
buckets are used to collect liquid sludge samples.
• Sample Location. If the permit does not identify a specific sludge sampling location, the
inspector must select one. See EPA's sewage sludge sampling video for an overview of
this process. EPA's 1989 POTW Sludge Sampling and Analysis Guidance Manual states
that for purposes of enforcement, sludge samples must come from the treatment unit
process immediately prior to sludge disposal or end use. Often, the last unit process is
one of the dewatering processes described in the accompanying technical guidance.
Table 10-3, from EPA's 1989 Sampling and Analysis Guidance Manual, suggests
appropriate sampling points for a variety of unit processes.
• Sample Collection Techniques. Obtaining a representative sample of sludge is difficult
when the sludge is not flowing through a pipe or along a conveyer. To obtain a
representative sample of sludge from a sludge bed or lagoon, a compost pile, or a truck,
several samples have to be taken from various places in the pile and "combined" to make
a representative sample.
• Sample Preservation. Samples of solid sludge are not usually preserved in the field
because it is difficult to thoroughly mix the preservative throughout the sludge sample. It
is best to preserve sludge samples that are high in solids at the laboratory. The
appropriate field preservative outlined in Appendix J is to chill the sample to 4°C.
Laboratory Analysis and Quality Assurance
During a PAI, the inspector is already conducting an in-depth evaluation of the permittee's
laboratory analytical techniques and QA/QC procedures. The following elements are
evaluated during this inspection:
• Permittee sample handling procedures in the laboratory
• Laboratory analysis techniques
- Permittee laboratory analytical procedures (Analytical methods specified by 40 CFR
Part 503 or other methods established in the permit)
- Laboratory services
- Instruments and equipment
- Supplies
• QA/QC
- Precision and accuracy of the measurement process
- Data handling and reporting
- Sludge records retention (for 5 years)
- Personnel qualifications.
10-17
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Chapter Ten Sewage Sludge
Again, many of these elements are evaluated according to the same criteria regardless of the
sample being analyzed. The inspector is referred to Chapter 7 and the 1990 NPDES
Compliance Monitoring Inspector Training Module on Laboratory Analysis for general guidance
on inspecting the permittee's laboratory procedures. There are some differences in sample
preparation and analytical techniques for sludge with which the inspector should be familiar.
In conducting the sludge component of the PAI, the inspector should closely evaluate the
permittee's sample preparation procedures. The sludge matrix is more complex and variable
than the wastewater matrix; therefore, the laboratory's development of sample preparation
techniques is of particular concern.
The NPDES permit may require the permittee to analyze sludge for conventionals, inorganic
pollutants, metals, and pathogens (depending on the ultimate sludge disposal practice). For
example, sludge that is going to be land applied will be analyzed for 10 metals and nitrogen to
determine the appropriate application rate. Table 10-8 lists the constituents required to be
monitored by Part 503. 40 CFR 503.8 contains a listing of approved analytical methods and
volatile solids reduction calculations that must be used for monitoring sludge quality. The
analytical methods for metals are not the same as those used for the analysis of wastewater.
Appendix J contains the required analytical method, the maximum allowable sample holding
times, sample preservation techniques, sample containers, sample preparation methods, and
additional comments that may be pertinent to the analytical method.
The inspector should keep the following points in mind when reviewing the permittee's lab and
analytical results:
• The Part 503 standards are expressed on a dry weight basis. Laboratory results for
sludge are typically reported in one of two forms, wet weight (i.e., mg/L) or dry weight
(i.e., mg/kg). The laboratory should be providing the results on a dry weight basis. In
the event that the laboratory results are reported on a wet weight basis (i.e., in mg/L),
the results for each pollutant in each sample must be recalculated to determine the dry
weight concentration. To accomplish this conversion, the percent total solids in the
sludge sample must be known. Thus, the lab must analyze the sample for percent
solids using Method 2540G of Standard Methods, 18th Edition.
The following equation can be used to determine the dry weight concentration because
the equation uses the assumption that the specific gravity of water and sewage sludge
are both equal to one. However, this assumption holds true only when the solids
concentration in the sludge is low. The calculated dry weight concentration may vary
slightly from the actual concentration as the solids content increases because the
density of the sewage sludge may no longer be equal to that of water. Typically, this
concern does not arise because the solids content of sludge is usually low. EPA is
aware of this potential problem and may make a determination regarding this matter at
a later date.
10-18
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Chapter Ten Sewage Sludge
Determine the pollutant concentration on a dry weight basis using the following
abbreviated conversion:1
PC (dry, mg/kg) = PC
-------
Chapter Ten Sewage Sludge
Table 10-1
Records Relevant for Sludge Operations
Sludge Use/Disposal Records '
• Volume
• Type of use and/or disposal options used
• Use/disposal sites
• Loading rates of pollutants (e.g., cadmium and nitrogen) at each land-application
site
Sludge Operating Records
• Daily operating log
• Equipment maintenance scheduled and completed
• Detention time, operating temperature, or pH to evaluate pathogen reduction
Sludge Monitoring Records
Constituents/pollutants in sludge
Mass of sludge generated and disposed of (in dry metric tons per year)
Sludge Sampling and Analytical Data
Dates, times, and locations of sampling
Sampling protocols and analytical methods
Results of analyses
Dates and times of analyses
Name(s) of analysis and sampling personnel
Sludge Laboratory Records
• Calibration and maintenance of equipment
• Laboratory bench sheets or logs and calculations
• Quality Assurance/Quality Control (QA/QC) records
10-20
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Chapter Ten
Sewage Sludge
Table 10-12
Operating Records for Specific Unit Processes
-V .'•• «"• ' „ ,""•"' , '•,=;', , ,,,,,,, •«•» "-',.
Gravity Thickening
• Overflow volume
• Influent flow
• Percent solids
- Sludge feed
- Thickened sludge
- Overflow
• Sludge blanket depth
; **"4P^ 'r^KB^^flStttt
Aerobic Digestion
• Air supply
• Solids retention time
• Temperature
• DO level
•pH
• Feed sludge
- TS, TVS, and pH
- Flow rate
• Digested sludge
- SOUR
- TS, TVS, and pH
- Flow rate
• Supernatant
- Flow rate and BOD
- TSS and pH
Wet Air Oxidation
Temperature
• Pressure
• Detention time
• Sludge feed
- Percent solids
- Volatile solids
- Feed rate
• End product volatile solids
Chemical
Conditioning/Stabilization
• Chemical types and dosage
• Mixing
•pH
1 tftlCKEfJING pftQCEpSES
Dissolved Air Flotation
• Sludge feed rate
• Recycle flow
• Daily operating time
• Percent solids
- Sludge feed
- Thickened sludge
- Subnatant
Floating sludge depth
Air flow rate
Retention tank pressure
Percent solids capture
Detention time
Air to solid ratio
BOBSSSS"*{Pdlhog^h^nd/orrV6%
Anaerobic Digestion
• Detention time
• Temperature
• pH and alkalinity
• Gas production and quality
• Volatile acids
• Feed sludge
- TS, TVS, and pH
- Flow rate
• Digested sludge
- TS, TVS, and pH
- Flow rate
• Supernatant
- Flow rate and BOD
- TSS and pH
• Cleaning frequency
Heat Treatment
Temperature/time
• Pressure
• Feed sludge
- TS and TVS
- Flow Rate
- Percent solids
Electron Irradiation
• Sludge feed rate
• Electron dosage
• Temperature
Centrifuge
• Influent sludge flows
• Volume cake produced
• Percent solids
- Sludge feed
- Centrate
- Sludge cake
• Daily operating time
piptf^iQn^|dlj$ton^ , . "'•• ;>
Incineration
• Operating schedule
• Sludge feed
- Solids content
- Feed rate
- Volatile solids
Combustion temperature
Sludge residence time
Fuel flow
Off-gas oxygen content
Air feed rate
Emission control equipment
- Pressure drop
Type of fuel
Volume of ash produced
Stack gas monitoring
Composting
Oxygen concentration
• Temperature and time
• Turning frequency
• Percent sludge solids
• Type and amount of bulking
agent(s)
• Header pressure
Gamma Irradiation
• Sludge feed rate
• Gamma ray source strength
10-21
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Chapter Ten
Sewage Sludge
Table 10-2
Operating Records for Specific Unit Processes
(Continued)
'"'' , *•*'&$. '$ • •. >;i; . *: - >f©i6t6BI!fe-lJ|G®JBSS'::;- I ? '" - -
Vacuum Filter
• Sludge feed
- Total solids
• Sludge cake
- Total solids
• Filtrate
- Flow
- BOD
-TSS
• Maintenance
• Spare parts
Drying Bed
• Sludge loading rate
• Quantity in bed
• Depth of sludge in bed
• Date deposited
• Detention time
• Ambient temperature
• Drying bed construction
(i.e., lined)
• Undertrain destination
• Percent solids of the sludge
feed and of the dewatered
sludge
LEGEND:
DO = Dissolved Oxygen
TS = Total Solids
TVS = Total Volatile Solids
Pressure Filter
• Sludge feed percent
solids
• Sludge cake percent
solids
• Volume of sludge
processed
• Cycle length
• Volume conditioning
chemicals
• Filtrate
- Flow
-BOD
-TSS
Drying Lagoons
• Sludge loading rate
• Percent solids
- Sludge
- Decant
• Quantity in lagoon
• Depth in lagoon
• Date deposited
• Drying time
• Rainfall
Belt Filter Press
• Loading rate
• Operating speed
• Feed slurry
- Total solids and flow
• Dewatered sludge
- Total solids
- Flow
• Filtrate and wash water
- BOD and SS
- TSS and flow
• Preventive maintenance
• Polymer
Heat Drying
• Operating schedule
- Start-up
- Shut-down
• Sludge feed rate
• Percent solids
- Sludge feed
- Dewatered sludge
• Fuel consumption
• Air flow
• Drying temperature
• Detention time
• Stack gas monitoring
- Oxygen
- Particulates
- Carbon monoxide
- Carbon dioxide
BOD = Biochemical Oxygen Demand
TSS = Total Suspended Solids
SS = Suspended Solids
SOUR = Specific Oxygen Uptake
Rate
•
10-22
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Chapter Ten
Sewage Sludge
Table 10-3
Sludge Sampling Points
Sludge Type
Sampling Point
Anaerobically digested
Aerobically digested
Thickened
Heat treated
Dewatered by belt filter press,
plate and frame press,
centrifuge, or vacuum filter
press
Dewatered or air dried in
drying beds, or bin or truck bed
Composted
Sample from taps on the discharge side of positive
displacement pumps.
Sample from taps on the discharge lines from pumps. If
batch digester is used, sample directly from the digester.
Two cautionary notes regarding this practice:
• If aerated during sampling, air entrains in the sample.
Volatile organic compounds may purge with escaping
air.
• When aeration is shut off, solids separate rapidly in
well-digested sludge.
Sample from taps on the discharge side of positive
displacement pumps.
Sample from taps on the discharge side of positive
displacement pumps after decanting. Be careful when
sampling heat treatment sludge because of:
• High tendency for solids separation
• High temperature of samples (frequently >60°C) can
cause problems with certain sample containers due to
cooling and subsequent contraction of entrained
gases.
Sample from sludge cake discharge chute and conveyor.
Alternatively, sample from collection container or storage
bin for the dewatered sludge; sample from many
locations within the storage bin and at various depths,
collect equal samples from each point, and combine them
to form one sample of the total storage bin.
Divide bed into four quadrants, collect equal sample
volume from the center of each quadrant, and combine
them to form one sample of the total bed. Each grab
sample should include the entire depth of the sludge
(down to the sand).
Collect full core samples from randomly selected sites in
the pile. Sample directly from front-end loader or other
conveyance device as the sludge is being loaded into
trucks to be hauled away.
10-23
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Chapter Ten Sewage Sludge
Table 10-4
Recordkeeping Requirements for Class A
Pathogen Reduction Alternatives
Alternative A1—Time and Temperature
Analytical results for density of Salmonella sp. bacteria or fecal coliform (most probable number)
Sludge temperature
Time (days, hours, minutes) temperature maintained
Alternative A2—Alkaline Treatment
Analytical results for density of Salmonella sp. bacteria or fecal coliform (most probable number)
Sludge pH
Time (hours) pH maintained above 12 (at least 72 hours)
Sludge temperature
Percent solids in sludge after drying (at least 50 percent)
Alternative A3—Analysis and Operation
Analytical results for density of Salmonella sp. bacteria or fecal coliform (most probable number)
Analytical results for density of enteric viruses (plaque forming unit/4 grams total solids) prior to
pathogen reduction and, when appropriate, after treatment
Analytical results for density of viable helminth ova (number/4 grams total solids) prior to pathogen
reduction and, when appropriate, after treatment
Values or ranges of values for operating parameters to indicate consistent pathogen reduction
treatment
Alternative A4—Analysis Only
Analytical results for density of Salmonella sp. bacteria or fecal coliform (most probable number)
Analytical results for density of enteric viruses (plaque forming unit/4 grams total solids)
Analytical results for density of viable helminth ova (number /4 grams total solids)
10-24
-------
Chapter Ten
Sewage Sludge
Table 10-4
Recordkeeping Requirements for Class A
Pathogen Reduction Alternatives
(Continued)
Alternative AS — Processes to Further Reduce Pathogens (PFRP)
• Heat Drying
- Analytical results for density of
Salmonella sp. bacteria or fecal conform
(most probable number)
- Moisture content of dried sludge <10
percent
- Logs documenting temperature of sludge
particles or wet bulb temperature of exit
gas exceeding 80°C
• Thermophilic Aerobic Digestion
- Analytical results for density of
Salmonella sp. bacteria or fecal conform
(most probable number)
- Dissolved oxygen concentration in
digester <1 mg/L
- Logs documenting temperature
maintained at 55-60°C for 10 days
• Heat Treatment
- Analytical results for density of
Salmonella sp. bacteria or fecal coliform
(most probable number)
- Logs documenting sludge heated to
temperatures greater than 180°C for 30
minutes
• Pasteurization
- Analytical results for density of
Salmonella sp. bacteria or fecal coliform
(most probable number)
- Temperature maintained at or above
70°C for at least 30 minutes
• Composting
- Analytical results for density of
Salmonella sp. bacteria or fecal coliform
(most probable number)
- Description of composting method
- Logs documenting temperature
maintained at or above 55°C for 3 days if
within vessel or static aerated pile
composting method
- Logs documenting temperature
maintained at or above 55°C for 15 days
if windrow compost method
- Logs documenting compost pile turned at
least five times per day, if windrow
compost method
• Gamma Ray Irradiation
- Analytical results for density of
Salmonella sp. bacteria or fecal coliform
(most probable number)
- Gamma ray isotope used
- Gamma ray dosage at least 1 .0 megarad
- Ambient room temperature log
• Beta Ray Irradiation
- Analytical results for density of
Salmonella sp. bacteria or fecal coliform
(most probable number)
- Beta ray dosage at least 1 .0 megarad
- Ambient room temperature log
Alternative A6— PFRP Equivalent
• Operating parameters or pathogen levels as necessary to demonstrate equivalency to the
PFRP
• Analytical results for density of Salmonella sp. bacteria or fecal coliform (most probable
number)
10-25
-------
Chapter Ten Sewage Sludge
Table 10-5
Recordkeeping Requirements for Class B
Pathogen Reduction Alternatives
Alternative B1—Fecal Coliform Count
• Number of samples collected during each monitoring event
• Analytical results for density of fecal coliform for each sample collected
Alternative B2—Processes to Significantly Reduce Pathogens (PSRP)
• Aerobic Digestion
- Dissolved oxygen concentration
- Volatile solids content before and after digestion
- Mean residence time of sludge in digester
- Logs showing temperature was maintained for sufficient period of time (ranging from
60 days at 15°C to 40 days at 20°C)
• Air Drying
- Description of drying bed design
- Depth of sludge on drying bed
- Drying time in days
- Daily average ambient temperature
• Anaerobic Digestion
- Volatile solids content before and after digestion
- Mean residence time of sludge in digester
- Temperature logs of sludge in digester
• Composting
- Description of composting method
- Daily temperature logs documenting sludge maintained at 40°C for 5 days
- Hourly readings showing temperature exceeded 55°C for 4 consecutive hours
• Lime Stabilization
- pH of sludge immediately and then 2 hours after addition of lime
Alternative B3—PSRP Equivalent
Operating parameters or pathogen levels as necessary to demonstrate equivalency to
PSRP
10-26
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Chapter Ten
Sewage Sludge
Table 10-6
Recordkeeping Requirements for Vector Attraction
Reduction Sludge Processing Options
Option 1— Volatile Solids (VS) Reduction
• Volatile solids concentration of raw and
final sludge streams (mg/kg)
• Calculations showing 38 percent reduction
in volatile solids
Options 2 and 3 — Bench-Scale VS
Reduction
• One-time description of bench-scale
digester
• Time (days) that sample was further
digested in bench-scale digester (30 days
for aerobically and 40 days for
anaerobically digested sludge)
• Temperature logs showing temperature
maintained at 20°C for aerobically or
between 30°C and 37°C for anaerobically
digested sludge
• Volatile solids concentration of sludge
(mg/kg ) before and after bench-scale
digestion
Option 4 — Specific Oxygen Uptake Rate
• Dissolved oxygen readings for sludge
sample over 15-minute intervals (mg/L)
• Temperature logs showing test was
conducted at 20°C
• Total solids for sludge sample (g/L)
• SOUR calculations (mg/g)
Option 5 — Aerobic
Processing(Thermophilic Aerobic
Digestion/Composting)
• Sludge detention time in
digester/composting
• Temperature logs showing average
temperature above 45°C and minimum
temperature above 40°C for 14
consecutive days
Options 6 — Alkaline Treatment
• Logs demonstrating hours pH of sludge/
alkaline mixture was maintained (1 2 for 2
hours and 1 1 .5 for an additional 22 hours)
• Amount of alkaline added to sludge (Ibs
or gals)
• Amount of sludge treated
Options 7 and 8 — Drying
• Results of percent solids (dry weight) test
• Presence of unstabilized solids generated
during primary treatment
10-27
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Chapter Ten " Sewage Sludge
Table 10-7
Sludge Handling Process Evaluation
General Indicators
• Inadequate sludge removal from clarifiers or thickeners
• Substantial down-time of sludge treatment units/solids handling
• Sludge disposal inadequate to keep treatment system in balance
• Mass balance inappropriate (ratio of sludge wasted should be 0.65-0.85 Ibs of sludge per Ib of
BOD removed)
Sludge Thickening Problems
• Sludge decant or return flows high in solids*
• Thickened sludge too thin
• Fouling of overflow weirs on gravity thickeners
• Air flotation skimmer blade binding on beaching plate
Anaerobic Digestion Problems
Sludge heater inoperative*
Supernatant exuding sour odor*
Inadequate gas production*
Mechanical or gas mixers inoperative
Floating cover of anaerobic digester tilting
Gas burner inoperative
pH problems*
Excessive suspended solids in supernatant
Aerobic Digestion Problems
Excessive foaming in tank*
Objectionable odor in aerobically digested sludge*
Insufficient DO in digester
Digester overloaded
Clogging of diffusers in digester
Mechanical aerator failure in digester
Inadequate supernatant removal
Drying Beds/Lagoons Problems
Dry sludge stacked around drying beds where runoff may enter waters
Broken dikes between sludge drying lagoons
Poor sludge distribution on drying beds
Vegetation in drying beds (unless reed design)
Inadequate drying time on drying beds
Dry sludge remaining on drying beds
Objectionable odor from sludge lagoon
Unlined sludge lagoons
Sludge Dewatering Problems
• Excessive solids present in dewatering filtrate*
• Inadequate dryness of sludge cake*
• Sludge build-up on belts, rollers, or conveyors of dewatering equipment
• Insufficient run time for sludge dewatering equipment
indicates serious problems with the sludge handling process.
10-28
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Chapter Ten Sewage Sludge
Table 10-7
Sludge Handling Process Evaluation (Continued)
Disposal
• Sludge constituents not analyzed before disposal
• Sludge not transported in appropriate approved vehicle
• Objectionable odors generated at sludge disposal site*
• Inadequate runoff control at landfill or land application sites
• Inadequate coverage of sludge in subsurface injection system
• Slow drying of soil-sludge mixture in subsurface injection system
• Sludge ponding at land application sites
• Inadequate burial of sludge at landfill site
• Liquid sludge applied to landfill site or sludge fails paint filter test
• Excessive erosion at sludge sites
• Sludge disposed of in nonpermitted sites
• Sludge lagoons full and overflowing*
indicates serious problems with the sludge handling process.
10-29
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Chapter Ten
Sewage Sludge
Table 10-8
Pollutants Monitored for Land Application, Surface Disposal, and Incineration
Pollutant
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Nitrogen
Land Application
/
/
/
/
/
/
/
/
/
/ ,
/
Surface Disposal
(unlined units)
/
/
/
Incineration
/
/
/
/
/
/
/
Organism to Be Monitored
Fecal Coliform(1)
Salmonella sp.(1) bacteria (in
lieu of fecal coliform)
Enteric Viruses*2'
Viable Helminth'2' Ova
Fecal Coliform(3)
Allowable Level in Sludge
1 ,000 Most Probable Number (MPN) per gram (Class A) of
total solids (dry weight)
3 MPN per 4 grams total solids (dry weight)
Less than one plaque-forming unit per 4 grams total solids
(dry weight)
Less than one viable helminth ovum per 4 grams of total
solids (dry weight)
Less than 2 x 106 MPN or less than 2 x 106 colony-forming
units per gram of total solids (dry weight) (expressed as
geometric mean of the results of 7 individual samples)
(1)
All Part 503 Class A Alternatives 1, 2, 3, 4, 5, 6
(2) Class A Alternatives 3 and 4 only
(3) Class B, Alternative 1
10-30
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10. SEWAGE SLUDGE
C. References
References
I. GENERAL
Clark, J.W., W. Wiessman and M. Hammer, Water Supply Pollution Control. (Harper and Row
Publishers, 1977).
Code of Federal Regulations. Standards for the Use or Disposal of Sewage Sludge. 40 CFR
Part 503, FR 9387.
Gulp, G.L., and N. Folks Heim. January 1978. Field Manual for Performance Evaluation and
Troubleshooting at Municipal Wastewater Treatment Facilities. U.S. Environmental Protection
Agency, EPA 430/9-78-001.
Hinrichs, D.J. Inspectors Guide for Evaluation of Municipal Wastewater Treatment Plants.
April 1979. U.S. Environmental Protection Agency, 430/9-79-010.
Metcalf and Eddy Inc. Wastewater Engineering: Treatment Disposal/Reuse. (McGraw-Hill
Book Company, 1979).
Steel, E.W., and T.J. McGhee, Water Supply and Sewerage. (McGraw-Hill Book Company,
1979).
U.S. Congress. March 1985, Overview of Sewage Sludge and Effluent Management. Office
of Technology Assessment, C/R-36b/#10.
U.S. Environmental Protection Agency. January 1975. Process Design Manual for
Suspended Solids Removal. EPA 625/1-75-0032.
U.S. Environmental Protection Agency. April 1976. Municipal Sludge Management: EPA
Construction Grants Program. Office of Water Program Operations, EPA 430/9-76/009.
U.S. Environmental Protection Agency. October 1977. Municipal Sludge Management:
Environmental Factors. Office of Water Program Operations, EPA 430/9-77/004.
U.S. Environmental Protection Agency. 1978. Operations Manual, Sludge Handling and
Conditioning. Office of Water Program Operations, EPA 430/9-78-002.
U.S. Environmental Protection Agency. September 1979. Process Design Manual for Sludge
Treatment and Disposal. Municipal Environmental Research Laboratory, EPA 625/1-79-011.
U.S. Environmental Protection Agency. February 1980. Evaluation of Sludge Management
Systems. Office of Water Program Operations, EPA 430/9-80-001, MCD-61.
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Chapter Ten Sewage Sludge
U.S. Environmental Protection Agency. September 1984. Use and Disposal of Municipal
Wastewater Sludge. Intra-Agency Sludge Task Force, EPA 625/10-84-003.
U.S. Environmental Protection Agency. July 1985. Summary of Environmental Profiles and
Hazard Indices for Constituents of Municipal Sludge. Office of Water Regulations and
Standards.
U.S. Environmental Protection Agency. 1987. Advanced Waste Treatment — Field Study
Training Program.
II. SAMPLING SLUDGE QUALITY
U.S. Environmental Protection Agency. August 1989. POTW Sludge Sampling and Analysis
Guidance Document. Office of Water Enforcement and Permits.
U.S. Environmental Protection Agency. August 1988. Sampling Procedures and Protocols for
the National Sewage Sludge Survey. Office of Water Regulations and Standards.
U.S. Environmental Protection Agency. September 1990. Analytical Methods for the National
Sewage Sludge Survey. Office of Water Regulations and Standards.
U.S. Environmental Protection Agency. 1993. Sewage Sludge Sampling Techniques Video.
III. PATHOGENS
U.S. Environmental Protection Agency. December 1992. Control of Pathogens and Vector
Attraction in Sewage Sludge. Office of Research and Development, EPA 625/R-92/013.
U.S. Environmental Protection Agency. September 1989. Control of Pathogens in Municipal
Wastewater Sludge. Center for Environmental Research Information, EPA 625/10-89/006.
U.S. Environmental Protection Agency. December 1973. Pathogen Risk Assessment
Feasibility Study. Office of Research and Development, EPA 670/2-73/098.
IV. LAND APPLICATION
Loeht, R.C. Pollution Control for Agriculture. Academic Press Inc., 1984.
U.S. Environmental Protection Agency. August 1993. Preparing Sewage Sludge for Land
Application or Surface Disposal; A Guide for Preparers of Sewage Sludge on the Monitoring,
Recordkeeping, and Reporting Requirements of the Federal Standards for the Use or Disposal
of Sewage Sludge in 40 CFR Part 503. Office of Water, EPA 831 B-93-002a.
U.S. Environmental Protection Agency. Land Application of Sewage Sludge; A Guide for Land
Appliers on the Recordkeeping and Reporting Requirements of the Federal Standards for the
Use and Disposal of Sewage Sludge Management in 40 CFR Part 503.
U.S. Environmental Protection Agency. October 1983. Land Application of Municipal Sludge,
Municipal Environmental Research Laboratory, EPA 625/1-83/016.
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Chapter Ten Sewage Sludge
U.S. Environmental Protection Agency. November 1976. Application of Sewage Sludge to
Cropland; Appraisal of Potential Hazards of the Heavy Metals to Plants and Animals. Office of
Water Program Operations, EPA 430/9-76/013.
U.S. Environmental Protection Agency. June 1978. Applications of Sludge on Agricultural
Land. Municipal Construction Division, Office of Research and Development, EPA 600/
2-78/131 b.
U.S. Environmental Protection Agency. October 1981. Land Treatment of Municipal
Wastewater. EPA Center for Environmental Research Information, EPA 625/1-81-013.
U.S. Environmental Protection Agency. June 1978. Sewage Disposal on Agricultural Soils:
Chemical and Microbiological tmplications. Office of Research and Development, EPA 600/
2-78/131 b.
V. LANDFILLING
U.S. Environmental Protection Agency. May 1994. Surface Disposal of Sewage Sludge; A
Guide for Owners/Operators of Surface Disposal Facilities on the Monitoring, Recordkeeping,
and Reporting Requirements of the Federal Standards for the Use and Disposal of Sewage
Sludge in 40 CFR Part 503.
U.S. Environmental Protection Agency. October 1978. Municipal Sludge Landfills.
Environmental Research Information Center, Office of Solid Waste, EPA 625/1-78/010, SW-
705.
VI. DISTRIBUTION AND MARKETING
U.S. Environmental Protection Agency. August 1985. Composting of Municipal Wastewater
Sludges. EPA Center for Environmental Research Information, EPA 625/4-85-014.
U.S. Environmental Protection Agency. June 1981. Composting Processes to Stabilize and
Disinfect Municipal Sewage Sludge. Office of Water Program Operations, EPA 430/9-81 -011,
MCD-79.
VII. INCINERATION
U.S. Environmental Protection Agency. September 1985. Municipal Wastewater Sludge
Combustion Technology. EPA Center for Environmental Research Information, EPA 625/4-85-
015.
VIII. MISCELLANEOUS
U.S. Environmental Protection Agency. September 1987. Dewatering Municipal Wastewater
Sludges, Office of Research and Development. EPA 625/1-87/014.
U.S. Environmental Protection Agency. December 1973. Odors Emitted From Raw and
Digested Sewage Sludge. Office of Research and Development, EPA 670/2-73/098.
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Chapter Ten Sewage Sludge
U.S. Environmental Protection Agency. October 1982. Process Design Manual for
Dewatering Municipal Wastewater Sludges. Office of Research and Development, EPA 625/1 -
82-014.
U.S. Environmental Protection Agency. April 1986. Radioactivity of Municipal Sludge. Office
of Water Regulations and Standards.
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11. STORM WATER
Contents Page
A. Review of the Storm Water Regulations
Development of Storm Water Regulations (40 CFR §122.26) 11-1
Applicability of Storm Water Discharges Associated With Industrial Activity 11-2
Permit Applications for Storm Water Discharges Associated With Industrial Activity . 11-5
Applicability of Storm Water Discharges From Municipal Separate Storm
Sewer Systems 11-7
Permit Applications for Storm Water Discharges From Municipal Separate Storm
Sewer Systems 11-7
Storm Water Application and Permitting Deadlines 11-7
t
B. Storm Water Permits
Typical Storm Water Discharge Permit Contents for Industrial Activities 11-15
Storm Water Pollution Prevention Plans 11-15
Typical Storm Water Discharge Permit Contents for Municipal Separate Storm
Sewer Systems 11-20
Storm Water Management Programs 11-21
C. Sampling and Inspection Considerations
Storm Water Pollutant Sources 11-27
Storm Water Sampling Considerations 11-29
Flow Measurement Considerations 11-31
Inspecting for Illicit Connections 11-31
D. References
Regulations/Notices . t1 -37
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Chapter Eleven Contents
List of Tables
11-1. Summary of 40 CFR 122.26 Storm Water Permitting Regulations 11-11
11-2. Important SIC Codes for Storm Water Discharges 11-12
11-3. NPDES Storm Water Permit Application and Issuance Deadlines 11-13
List of Figures
11-1. Industrial Categories Associated With Industrial Activity 11-9
11-2. Site-Specific Industrial Storm Water BMPs 11-25
11-3. Site-Specific Construction Storm Water BMPs 11-26
Associated Appendices
K EPA Industrial General Permit Checklist Storm Water Pollution Prevention Plan Analysis
L Industrial Source Control BMP Questions
M EPA Baseline Construction General Permit Requirements Pre-Construction Checklist
N Construction Source Control BMP Questions
O Monitoring Requirements in EPA's General Permit
P Rain Zones of the United States
Q Typical "c" Coefficients
11-ii
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11. STORM WATER
A. Review of the Storm Water
Regulations
Development of Storm Water Regulations (40 CFR §122.26)
The 1972 amendments to the Federal Water Pollution Control Act (also known as the Clean
Water Act or CWA) prohibited the discharge of any pollutants to navigable waters from a point
source unless the discharge is authorized by a National Pollutant Discharge Elimination
System (NPDES) permit. At the time of the 1972 amendments to the CWA, sewage treatment
plant outfalls and industrial process wastewater were easily identified as point sources
responsible for contributing to the degradation of water quality. However, as pollution control
measures were instituted, it became evident that more diffuse sources, such as agricultural
and urban storm water runoff, were also contributing to the problem. In response to this
concern, the Water Quality Act (WQA) of 1987 added section 402(p) to the CWA and required
the Environmental Protection Agency (EPA) to establish a comprehensive two-phased
approach to address storm water discharges.
In response to section 402(p)(2) of the CWA, EPA finalized Phase I storm water regulations,
published on November 16, 1990 (57 FR 47990). The regulations specify that by October 1,
1992, the following point source1 storm water discharges must apply for a NPDES permit: (i)
a discharge with respect to which a permit has been issued prior to February 4, 1987; (ii) a
discharge associated with industrial activity (see §122.26(a)(4)); (iii) a discharge from a large
municipal separate storm sewer system; (iv) a discharge from a medium separate storm
sewer system; and (v) a discharge that the Director, or in States with approved NPDES
programs, either the Director or the EPA Regional Administrator determines is contributing to
a violation of a water quality standard or is a significant contributor of pollutants to waters of
the United States. The regulations exempt "discharges of storm water runoff from mining
1 Point source storm water discharge does not include "sheet flow" (SFL) off of an industrial facility. A
point source is defined at 40 Code of Federal Regulations §122.2 as "any discernible, confined, and
discrete conveyance, including but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete
fissure, container, rolling stock, concentrated animal feeding operation, landfill leachate collection system,
vessel or other floating craft from which pollutants are or may be discharged. This term does not include
return flows from irrigated agriculture or agricultural storm water runoff." Further, any discharge from an
industrial facility through a municipal separate storm sewer system is considered to be 'discharge
associated with industrial activity" and, therefore, covered by the storm water permitting requirements. In
most court cases, the term "point source" has been interpreted broadly. For example, the holding in Sierra
Club v. Abston Construction Co., Inc., 620 F.2d 41 (5th Cir. 1980) indicates that changing the surface of
land or establishing grading patterns on land will result in a point source where runoff from the site is
ultimately discharged to waters of the United States. The CWA does not relieve the discharger from liability
simply because the facility did not actually construct conveyances for the storm water. Conveyances
formed by erosion or other natural means may fit the CWA definition of point source and thereby subject
the dischargers to liability.
11-1
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Chapter Eleven Storm Water
operations or oil and gas exploration, production, processing or treatment operations or
transmission facilities, composed entirely of flows which are from conveyances or systems of
conveyances used for collecting and conveying precipitation runoff and which are not
contaminated by contact with or that has not come into contact with, any overburden, raw
material, intermediate products, finished product, byproduct or waste products located on the
site of such operations" [40 CFR §122.26(a)(2)]. An outline of these regulations, found in 40
CFR §122.26 (Storm water discharges), is presented in Table 11-1.
To incorporate the storm water regulations, EPA also had to revise language in 40 CFR
§§122.1, 122.21, 122.22, 122.28, 122.42, 123.25, and 124.52. In general, revisions to these
sections were to incorporate references to specific storm water requirements, as identified in
40 CFR §122.26.
Phase II of the storm water program is currently under development and has not yet been
proposed. Therefore, the remainder of this chapter will focus on Phase I storm water
discharges.
Applicability of Storm Water Discharges Associated With Industrial Activity
First, the inspector must determine whether an industrial facility is subject to the storm water
permitting regulations. The storm water regulations identify 10 different major industrial
categories that are associated with industrial activity (40 CFR §122.26(b)(14)(i)-(x)), including
construction sites larger than 5 acres. EPA identified an eleventh category for "light"
industries, to be subject to the regulations only if there was an exposure of industrial
pollutants to storm water.1 A description of these 11 categories is provided in Figure 11-1. It
has been estimated that more than 100,000 facilities are covered by the regulations. The
discharges associated with these industrial activities are regulated pursuant to 402(p)(2)(B) of
the CWA, requiring the facility to apply for and obtain a permit to discharge storm water.
Point source discharges directly to waters of the United States and to municipal separate
storm sewer systems are covered by the storm water regulations; discharges to Publicly
Owned Treatment Works (POTWs) or combined sewer systems are not covered. The
inspector should be aware that on any given site, storm water may discharge at several
points: overland flow directly to a river or creek, though an inlet to a separate storm sewer
collection system, or to a combined sewer collection system that ultimately discharges to a
POTW.
For the light industries identified in 122.26(b)(14)(xi), "storm water discharges associated with
industrial activity," the regulations include only storm water discharges where material handling
1On June 4,1992, the U.S. Court of Appeals for the Ninth Circuit issued its opinion generally
affirming EPA's November 16,1990, Storm Water Application Regulations. Natural Resources
Defense Council v. EPA, 966 F.2d 1292 (9th Cir. 1992)(NRDC). The Court in NRDC did
invalidate and remand for further rulemaking the exemption of construction sites smaller than 5
acres and the exemption of certain "light" industries whose industrial activities are not exposed
to rain water. EPA is not requiring permit applications for these activities until further rulemaking
is completed.
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Chapter Eleven Storm Water
equipment or activities, raw materials, intermediate products, final products, waste materials,
by-products, or industrial machinery are exposed to storm water. Material handling activities
include the storage, loading and unloading, transportation, or conveyance of any raw material,
intermediate product, by-product or waste product. The term excludes areas located on plant
lands separate from the plant's industrial activities, such as office buildings and accompanying
parking lots as long as the drainage from the excluded areas is not mixed with storm water
drained from the above described areas.
A light industrial facility that determines that there is no exposure to storm water should
document the facility evaluation that led to this conclusion. A copy of this documentation
should be retained onsite. (Some States may have specific requirements for documenting
and retaining this information onsite.)
Operators of industrial facilities that are Federally, State, or municipally owned or operated
that meet the descriptions of the facilities listed in 40 CFR §122.26(b)(14)(i)-(xi) must also
submit applications.
The regulations, at 40 CFR 122.26(b)(14), define "storm water discharges associated with
industrial activity." Specifically, the phrase means "the discharge from any conveyance which
is used for collecting and conveying storm water and which is directly related to
manufacturing, processing or raw materials storage areas at an industrial plant." The
inspector will need to determine which areas are included in this definition. For the 10
categories of industries identified in 40 CFft §122.26(b)(14)(i)-(x), the term includes, but is not
limited to, storm water discharges from the following:
• Industrial plant yards
• Immediate access roads and rail lines used or traveled by carriers of raw materials,
manufactured products, waste material, or by-products used or created by the facility
• Material handling sites
• Refuse sites
• Sites used for the application or disposal of process wastewaters (as defined at 40
CFR Part 401)
• Sites used for the storage and maintenance of material handling equipment
• Sites used for residual treatment, storage, or disposal
• Shipping and receiving areas
• Manufacturing buildings
• Storage areas (including tank farms) for raw materials and intermediate and finished
products
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Chapter Eleven Storm Water
• Areas where industrial activity has taken place in the past and significant materials
remain and are exposed to storm water.
Also, the inspector must know which materials are considered significant. Significant
materials, defined at 40 CFR §122.26(b)(12), include, but are not limited to:
• Raw materials
• Fuels
• Materials such as solvents, detergents, and plastic pellets
• Finished materials such as metallic products
• Raw materials used in food processing or production
• Hazardous substances designated under section 101(14) of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA)
• Any chemical the facility is required to report pursuant to section 313 of Title III of
Superfund Amendments and Reauthorization Act (SARA)
• Fertilizers
• Pesticides
• Waste products such as ashes, slag, and sludge that have the potential to be released
with storm water discharges.
Identifying whether or not a facility actually performs activities that are subject to storm water
permitting requirements can be a complicated task. To allay concerns, EPA prepared two
guidance documents to provide interested parties with answers to many commonly asked
questions about storm water permitting requirements, NPDES Storm Water Program Question
and Answer Document (March 1992) and NPDES Storm Water Program Question and Answer
Document, Volume II (July 1993).
These two documents address:
• Facilities subject to storm water effluent guidelines, toxic pollutant effluent standards,
and new source performance standards
• Evaluating the applicability of storm water regulations to process operations in
categories (iii) mining and oil and gas operations, (iv) hazardous waste treatment,
storage, and disposal facilities, (v) landfills, land application sites, and open dumps, (vi)
recycling facilities, (vii) steam electric power generating facilities, (viii) transportation
facilities, (ix) sewage treatment facilities, (x) construction activities, and (xi) light
manufacturing facilities
• Individual, group, and general storm water discharge permits and permit applications
11-4
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Chapter Eleven Storm Water
• Sampling protocols
• Phase II storm water regulations
• General storm water information such as EPA and State contacts, definitions, and
program status.
It is strongly recommended that the inspector either have copies or be familiar with the
contents of these documents to support storm water permitting applicability decisions.
One of the first questions that must be answered when evaluating the applicability of the
storm water permitting regulations is whether the facility performs any industrial activities
subject to the storm water permitting requirements. Often, this decision hinges upon the
facility's primary Standard Industrial Classification (SIC) code, which is based on the primary
activity occurring at the site. Where multiple activities are conducted at a site, with each
activity having a distinct SIC code, EPA recommends using the value of receipts or revenues
with the activity generating the most revenue or employing the most people being the primary
activity of the facility. If this primary activity is identified in 40 CFff §122.26(b)(14), then the
facility is subject to the storm water permitting requirements. If, however, the facility's primary
activity is not included in 40 CFfl§122.26(b)(14), the facility is not subject to the permitting
requirements even if the facility conducts secondary activities that are identified therein.
Permit Applications for Storm Water Discharges Associated With Industrial Activity
The November 16, 1990, regulations specify three types of permit applications for storm water
discharges associated with industrial activity: individual permit applications, group permit
applications, and general permit applications. (Later, EPA published a series of general
permits in States, in Federal facilities, and on Indian lands, where EPA is the NPDES
permitting authority—57 F/741176, 57 FR 41236 for industrial activities [September 9, 1992];
57 FR 44412, 57 FR 44438 for construction activities [September 25, 1992].) Facilities
subject to the storm water permitting regulations had the opportunity to apply for any of the
three types of permits. The due date for group applications has since passed, leaving new
facilities with two options, general or individual permits.
Individual permit application requirements are identified in 40 CFft§122.26(c)(1) and require
the applicant to provide comprehensive facility-specific information and quantitative storm
water sampling data on Forms 1 and 2F. Individual permit applications were due on October
1, 1992 for existing facilities. New facilities must submit this application 180 days prior to
commencement of industrial activity that may cause a storm water discharge; new
construction facilities must submit an application 90 days prior to commencement of
construction.
Group permit application requirements are identified in 40 CFR §122.26(c)(2) and allow
facilities with similar operations and storm water discharges to file a single two-part permit
application. Part 1 group permit applications were due to EPA on September 30, 1991, for all
industrial activities except those owned and operated by a municipality with a population of
less than 250,000. Municipalities with populations of less than 250,000 were required to
submit this application no later than May 18, 1992. Part 2 applications were due to EPA on
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Chapter Eleven Storm Water
October 1, 1992, for all industrial activities except those owned and operated by a municipality
with a population of less than 250,000. Municipalities with populations of less than 250,000
were required to submit this application no later than May 17, 1993.
Industrial facilities wishing to be covered under a general permit, which is the most common
permit choice by far, must file a Notice of Intent (NOI). The NOI is a simple one-page form
that notices EPA (or the NPDES-approved State) of the facility's intent to be covered under
the baseline general permitting requirements. Typically, coverage under the permit is
automatic two days after the post-marked date of the NOI. (Some delegated States have
varying time frames and some do not offer automatic coverage.) All NOIs for existing
industrial facilities were due on October 1, 1992; however, EPA is accepting NOIs after that
date (although, acceptance does not preclude EPA from taking enforcement action against the
permittee for failure to submit). The NOI requires general facility operator and site
information, site activities, and a signed certification attesting to the truth, accuracy, and
completeness of the NOI. Most facilities submitting NOIs do so assuming that the general
permit will be less stringent and cheaper (i.e., fewer pollutant limitations, monitoring
requirements, and reporting requirements) to comply with than an individual permit. Also,
preparing an NOI is less costly than completing a Form 2F (i.e., no sampling is required).
Many facilities submitting individual permit applications believe that their facility is cleaner than
the "genera! facility" and are looking for less stringent requirements than those in the general
permit. EPA and NPDES-approved states do have the right to refuse issuance of a general
permit and require submission of an individual permit application based on a review of the
NOI or other information.
As described above, EPA established October 1, 1992, as the latest date for any facility with a
discharge associated with industrial activity to submit either an individual or group application,
or to be covered by a promulgated general permit.
Also, operators of storm water discharges associated with industrial activities that discharge
through a large or medium separate storm sewer system must provide the operator of the
large or medium municipal separate storm sewer system with basic information on the facility
and its discharge (40 CFR §122.26(a)(4). This information includes:
• The name of the facility
• A contact person and phone number
• The location of the discharge
• A description, including SIC code, which best reflects the principal products or services
provided by each facility
• Any existing NPDES permits.
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Chapter Eleven Storm Water
Applicability of Storm Water Discharges From Municipal Separate Storm Sewer Systems
In addition to regulating discharges from the 11 categories of sites with industrial activities, the
storm water program regulates discharges from medium and large municipal separate storm
sewer systems.
The November 16, 1990, regulations identify a two-part storm water permit application process
for medium (serving a population of 100,000 or more, but fewer than 250,000) and large
(serving a population of more than 250,000) municipal separate storm sewer systems in 40
CFR §122.26(d), pursuant to 402(p)(2)(C)-(D) of the CWA. The regulations identify 220 cities
and counties that meet this requirement (and allow for case-by-case designations of other
municipal storm sewers to be included in these systems). In addition to the designated
counties and cities, other entities may be regulated such as Departments of Transportation or
flood control districts. To date, a total of approximately 815 entities (cities, counties, DOTs,
etc.) will be covered under 263 permits nationwide. Part 1 applications for municipal storm
sewer systems were due to EPA on November 18, 1991, (large systems) and May 18, 1992,
(medium systems). Part 2 applications for these permittees were due to EPA on November
16, 1992, (large systems) and May 17, 1993, (medium systems).
Permit Applications for Storm Water Discharges From Municipal Separate Storm Sewer
Systems
Operators of large and medium municipal separate storm sewer systems (and others as
designated by the Director) are required to submit a two-part jurisdiction- or system-wide
permit application. Part 1 of the application should include general applicant information
(including legal authorities), characterization of storm water and the source area, a description
of existing management programs, and available resources. Part 2 of the application requires
demonstration of adequate legal authority, a proposed program to monitor storm water
discharges and estimate pollutant loads, refinement of the source characterization, a proposed
management program and its anticipated effects, and an analysis of the fiscal expenditures to
implement and enforce storm water provisions.
The permitting authority may issue one system-wide permit covering all discharges from
municipal separate storm sewer systems or issue distinct permits for appropriate categories of
discharges. Also, the permitting authority may issue permits for other municipal separate
storm sewer systems on a system-wide or categorical basis. In many instances, these
permits will be unique to the individual permittee; therefore, a definitive discussion of the
permit requirements for the municipal separate storm sewer system permittees is not possible.
Storm Water Application and Permitting Deadlines
Section 402(p)(4) of the CWA identifies specific deadlines for the issuance or denial of all
storm water permits. However, since EPA was unable to promulgate its regulations by the
statutory deadline, the regulations require issuing or denying all storm water permits within
one year of the permit application regulatory deadline consistent with Congress' intent.
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Chapter Eleven Storm Water
Section 402(p)(4) also specifies that permits shall provide for compliance as expeditiously as
practicable, but in no event later than 3 years after the permit issuance date. A summary of
permit application and issuance deadlines is provided in Table 11-3.
The Transportation Act of 1991 modified the application deadlines for industrial activities
owned or operated by municipalities. Specifically, industrial activities owned or operated by
municipalities with populations between 100,000 and 250,000 (medium-sized municipalities)
and power plants, airports, and uncontrolled sanitary landfills owned or operated by
municipalities with populations less than 100,000 (small municipalities) must have submitted
Part 1 group applications by May 18, 1992, and Part 2 by May 17, 1993. Other industrial
activities owned or operated by municipalities with a population of less than 100,000 have
been placed into Phase II of the storm water program for future rulemaking.
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Chapter Eleven Storm Water
Figure 11-1.
Industrial Categories Associated With Industrial Activity
The eleven categories engaging in industrial activity are described below. Descriptions of
Standard Industrial Classification [SIC] codes applicable to the storm water regulations are
provided in Table 11-1.
(i) Facilities subject to storrn water effluent limitations guidelines, new source performance
standards, or toxic pollutant effluent standards under 40 CFR subchapter N (except
facilities with toxic pollutant effluent standards which are exempted under category (xi)
below;
(ii) Facilities classified as SIC 24 (except 2434), 26 (except 265 and 267), 28 (except
283), 29, 311, 32 (except 323), 33, 3441, and 373;
(iii) Facilities classified as SIC 10 through 14 (mineral industry) including, active or inactive
mining operations (except for areas of coal mining operations no longer meeting the
definition of a reclamation area under 40 CFR §434.11(1) because the performance bond
issued to the facility by the appropriate SMCRA authority has been released, or except for
areas of non-coal mining operations which have been released from applicable State or
Federal reclamation requirements after December 17, 1990) and oil and gas exploration,
production, processing, or treatment operations, or transmission facilities that discharge
storm water contaminated by contact with or that has come into contact with, any
overburden, raw material, intermediate products, finished products, byproducts or waste
products located on the site of such operations; (inactive mining operations are mining
sites that are not being actively mined, but which have an identifiable owner/operator;
inactive mining sites do not include sites where mining claims are being maintained prior to
disturbances associated with the extraction, beneficiation, or processing of mined
materials, nor sites where minimal activities are undertaken for the sole purpose of
maintaining a mineral claim);
(iv) Hazardous waste treatment, storage, or disposal facilities, including those that are
operating under interim status or a permit under subtitle C of RCRA;
(v) Landfills, land application sites, and open dumps that receive or have received any
industrial wastes (waste that is received from any of the facilities described under this
subsection) including those that are subject to regulation under subtitle D of RCRA;
(vi) Facilities involved in the recycling of materials, including metal scrapyards, battery
reclaimers, salvage yards, and automobile junkyards, including but not limited to those
classified as SIC 5015 and 5093;
(vii) Steam electric power generating facilities, including coal handling sites;
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Chapter Eleven Storm Water
Figure 11-1.
Industrial Categories Associated With Industrial Activity (Continued)
(viii) Transportation facilities classified as SIC 40, 41, 42 (except 4221-25), 43, 44, 45, and
5171 which have vehicle maintenance shops, equipment cleaning operations, or airport
deicing operations. Only those portions of the facility that are either involved in vehicle
maintenance (including vehicle rehabilitation, mechanical repairs, painting, fueling, and
lubrication), equipment cleaning operations, airport deicing operations, or which are
otherwise identified under paragraphs (i)-(vii) or (ix)-(xi) of this section are associated with
industrial activity;
(ix) Treatment works treating domestic sewage or any other sewage sludge or wastewater
treatment device or system, used in the storage, treatment, recycling, and reclamation of
municipal or domestic sewage, including land dedicated to the disposal of sewage sludge
that are located within the confines of the facility, with a design flow of 1.0 million gallons a
day (mgd) or more, or required to have an approved pretreatment program under 40 CFR
Part 403. Not included are farm lands, domestic gardens or lands used for sludge
management where sludge is beneficially reused and which are not physically located in
the confines of the facility, or areas that are in compliance with section 405 of the CWA;
(x) Construction activity including clearing, grading and excavation activities except:
operations that result in the disturbance of less than five acres of total land area which are
not part of a larger common plan of development or sale;
(xi) Facilities under SIC 20, 21, 22, 23, 2434, 25, 265, 267, 27, 283, 285, 30, 31 (except
311), 323, 34 (except 3441), 35, 36, 37 (except 373), 38, 39, 4221-4225, (and which are
not otherwise included within categories (i)-(x).
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Chapter Eleven
Storm Water
Table 11-1.
Summary of 40 CFR 122.26 Storm Water Permitting Regulations
40 CFR §122.26 Storm Water Discharges
§122.26(a) Permit requirements
§122.26(b) Definitions
§122.26(c) Application requirements for storm water discharges associated with
industrial activity
§122.26(d) Application requirements for large and medium municipal separate storm
sewer discharges
§122.26(e) Application deadlines
§122.26(f) Petitions
Appendix E Rainfall zones of the United States
Appendix F Incorporated places with populations greater than 250,000 according to latest
decennial census by Bureau of Census
Appendix G Incorporated places with populations greater than 100,000 and less than
250,000 according to latest decennial census by Bureau of Census
Appendix H Counties with unincorporated urbanized areas with a population of 250,000
or more according to the latest decennial census by the Bureau of Census
Appendix I Counties with unincorporated urbanized areas greater than 100,000, but less
than 250,000 according to the latest decennial census by the Bureau of
Census
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Chapter Eleven Storm Water
Table 11-2.
Important SIC Codes for Storm Water Discharges
SIC Description
MINING
10 Metal mining
12 Coal mining
13 Oil and gas extraction
14 Mining and quarrying or nonmetallic minerals, except fuels
MANUFACTURING
20 Food and kindred products
21 Tobacco products
22 Textile mill products
23 Apparel and other finished products made from fabrics and similar materials
24 Lumber and wood products, except furniture
• 2434 Wood kitchen cabinets
25 Furniture and fixtures
26 Paper and allied products
265 Paperboard containers and boxes
267 Converted paper and paperboard products, except containers and boxes
27 Printing, publishing, and allied industries
28 Chemicals and allied products
283 Drugs
285 Paints, varnishes, lacquers, enamels, and allied products
29 Petroleum refining and related industries
30 Rubber and miscellaneous plastic products
31 Leather and leather products
311 Leather tanning and finishing
32 Stone, clay, glass, and concrete products
323 Glass products, made of purchased glass
33 Primary metals industry
34 Fabricated metal products, except machinery and transportation equipment
3441 Fabricated structural metal
35 Industrial and commercial machinery and computer equipment
36 Electronic and other electrical equipment and components, except computer equipment
37 Transportation equipment
373 Ship and boat building and repairing
38 Measuring, analyzing, and controlling instruments; photographic, medical and optical goods; watches and clocks
39 Miscellaneous manufacturing industries
TRANSPORTATION, COMMUNICATIONS, ETC.
40 Railroad transportation
41 Local and suburban transit and interurban highway passenger transportation
42 Motor freight transportation and warehousing
4221 Farm product warehousing and storage
4222 Refrigerated warehousing and storage
4225 General warehousing and storage
43 United States Postal Service
44 Water transportation
45 Transportation by air
WHOLESALE TRADE
50 Wholesale trade - durable goods
5015 Motor vehicle parts, used
5093 Scrap and waste material
51 Wholesale trade - nondurable goods
5171 Petroleum bulk stations and terminals
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Chapter Eleven
Storm Water
Table 11-3.
NPDES Storm Water Permit Application and Issuance Deadlines
Type of Application/
Type of Discharge
Permit Application
Deadline
Permit Issuance
Deadline
- / .- ' - '-Jnau|W*M >«,••*> r^ ' v -^ ,'. 'X=," '^w-,.'^->;^^ *'" & %^%;X;: V" "'
Individual
Existing facilities
Facilities rejected from a group
application
New facilities
New construction facilities
Grgug
All industrial activities except
those owned or operated by a
municipality with a population of
less than 250,000
Industrial activities owned or
operated by a municipality with a
population of less than 250,000
General
Existing facilities
New facilities
October 1, 1992
October 1, 1992
180 days prior to commencement of
industrial activity
90 days prior to commencement of
construction
Parti
September 30,
1991
May 18, 1992
Part 2
October 1, 1992
May 17, 1993
October 1, 19921
2 days prior to commencement of
industrial activity or construction1
October 1, 1993
October 1 , 1 993
1 year after receipt of
complete permit
application
1 year after receipt of
complete permit
application
October 1 , 1 993
May 17, 1994
2 days after the date that
the notice of intent is
postmarked
2 days after the date that
the notice of intent is
postmarked
;-'.;.:• , ,>MttitMf^:^ " ,,.
Large municipal systems
Medium municipal systems
Designated municipal systems
Part 1
November 18,
1991
May 18, 1992
Part 2
November 16,
1992
May 17, 1993
determined by permitting authority
November 16, 1993
May 17, 1994
facilities applying for general permits must submit notices of intent (NOIs), rather than permit
applications.
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Chapter Eleven Storm Water
*** NOTES ***
11-14
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11. STORM WATER
B. Storm Water Permits
Typical Storm Water Discharge Permit Contents for Industrial Activities
It is likely that most storm water discharge permits will be modeled after EPA's baseline
general permit. As such, the inspector will find that these permits address applicability, storm
water Pollution Prevention Plans, effluent limitations, monitoring and reporting requirements,
standard permit conditions, special conditions, reopener language, and Notice of Termination
(NOT) provisions. The Pollution Prevention Plan is considered the most important
requirement of the general permit; the same is probably true for individual permits.
Storm Water Pollution Prevention Plans
The discussion that follows refers to the general permits issued by EPA on September 9 and
25 of 1992. These permits are available to facilities located in States that have not been
delegated NPDES permit authority. The inspector should review the facility's permit prior to
the inspection, especially if the permit is different from the general permit. Each industrial and
construction activity covered by the general permit must have a plan, tailored to site-specific
conditions and designed to control the amount of pollutants in storm water discharges from
the site. The inspector should verify that these plans have been updated as appropriate to
reflect current conditions at the site. The permitting authority typically has the right to review
and request changes in the Pollution Prevention Plan. Summaries of necessary components
of these plans for industrial and construction activities are provided below for each of the two
types of activities.
Pollution Prevention Plan for Industrial Activity
The Pollution Prevention Plan as required in the EPA storm water general permit for industrial
activities must be prepared on or before April 1, 1993, and the facility must be in compliance
with the Plan on or before October 1, 1993. New facilities must submit an NOI at least 48
hours prior to commencement of the industrial activity at the site. The Plan must be signed by
a responsible corporate official such as a president, vice president, or general partner. This
Plan is to be kept at the facility at all times and only has to be submitted for review when
requested by EPA or by the operator of the municipal/separate storm sewer system when the
facility discharges to a municipal/separate storm sewer. For large or complex facilities, the
inspector should request a copy of the plan prior to inspection, to be more familiar with the
facility during the inspection.
The Plan must contain a description of potential pollutant sources and a description of the
measures and controls to prevent or minimize pollution of storm water. Specifically, the
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Chapter Eleven Storm Water
inspector should review the description of potential pollutant sources to verify that it reflects
current conditions and includes:
• A map of the facility indicating the areas that drain to each storm water discharge point
• An indication of the industrial activities that occur in each drainage area
• A prediction of the pollutants that are likely to be present in the storm water
• A description of the likely sources of pollutants from the site
• An inventory of the materials that may be exposed to storm water
• The history of spills or leaks of toxic or hazardous materials for the past 3 years.
In addition, the inspector should verify that measures and controls described in the Plan, are
current, and include the following:
• Good housekeeping or upkeep of industrial areas exposed to storm water
• Preventative maintenance of storm water controls and other facility equipment
• Spill prevention and response procedures to minimize the potential for and the impact
of spills
• Testing of all outfalls to ensure there are no cross connections (i.e., only storm water is
discharged)
• Training of employees on pollution prevention measures and controls, and record-
keeping.
Checklists relating to specific elements of the storm water Pollution Prevention Plan analysis
for industrial activities are provided in Appendix K.
Specific inspector questions, that may be appropriate at a given industrial site, to assess
activity-specific source controls are presented in Appendix L. Site-specific Best Management
Practices (BMPs) for industrial activities are summarized in Figure 11-2.
The EPA general permit also requires that facilities:
• Identify areas with a high potential for erosion and the stabilization measures or
structural controls to be used to limit erosion in these areas
• Implement traditional storm water management measures (e.g., oil/water separators,
vegetative swales, detention ponds) where they are appropriate for the site.
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Chapter Eleven Storm Water
The Plan must also have provisions for two tiers of inspections to be performed by the facility.
The first tier consists of inspections of designated areas of equipment to be performed on a
regular interval determined by the facility. These routine inspections are intended to
determine the need for maintenance, good housekeeping, or other BMPs. The second tier of
inspection is the comprehensive site evaluation, which requires qualified personnel to:
• Look for evidence of pollutants entering the drainage system
• Evaluate the performance of pollution prevention measures
• Identify areas where the Plan should be revised to reduce the discharge of pollutants
• Document both the routine inspections and the annual site evaluation in a report.
The compliance site evaluation can be done less frequently than the routine inspection (but
not less than once per year). Documentation of both the routine inspections and the
comprehensive site compliance evaluation must be included in the Plan.
Additional Requirements for EPCRA 313 Facilities
The EPA baseline general permit also includes special requirements for facilities subject to
reporting requirements under Emergency Planning and Community Right-to-Know (EPCRA)
(also known as Title III of the Superfund Amendments and Reauthorization Act (SARA) of
1986). Specifically, facilities that have discharges associated with industrial activity and that
are subject to Section 313 of EPCRA for chemicals classified as Section 313 water priority
chemicals" are subject to additional requirements. "Section 313 water priority chemicals" are
defined in Part X Definitions of EPA's baseline general permit as "chemical or chemical
categories which: 1) are listed at 40 CFR 372.65 pursuant to Section 313 of EPCRA; 2) are
present at or above threshold levels at a facility subject to EPCRA Section 313 reporting
requirements; and 3) that meet at least one of the following criteria; (i) Are listed in Appendix
D of 40 CFR 122 on either Table II (organic priority pollutants), Table III (certain metals,
cyanides, and phenols) or Table V (certain toxic pollutants and hazardous substances); (ii) are
listed as a hazardous substance pursuant to section 311(b)(2)(A) of the CWA at 40 CFR
116.4; or (iii) are pollutants for which EPA has published acute or chronic water quality
criteria."
Facilities that have discharges associated with industrial activity and that are subject to
Section 313 of EPCRA for chemicals classified as Section 313 water priority chemicals are
required to monitor storm water from the facility that comes into contact with any equipment,
tank, container, or other vessel or area used for storage of a Section 313 water priority
chemical, or located at a truck or rail car loading or unloading area where a Section 313 water
priority chemical is handled. Pollutants that must be monitored semiannually include Oil and
Grease (O&G), Biochemical Oxygen Demand (BOD5), Chemical Oxygen Demand (COD),
Total Suspended Solids (TSS), Total Kjeldahl Nitrogen (TKN), phosphorus, pH, acute whole
effluent toxicity, and any Section 313 water priority chemical for which the facility is subject to
reporting requirements under Section 313 of EPCRA.
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Chapter Eleven Storm Water
Reports, summarizing the monitoring results obtained must be submitted annually, on the 28th
day of the following January.
In addition to monitoring requirements, appropriate containment, drainage control, and/or
diversionary structures must be provided in areas where Section 313 water priority chemicals
are stored, processed, or otherwise handled. At a minimum, facilities must use either (1)
curbing, culverting, gutters, sewers or other forms of drainage control to prevent or minimize
the potential for storm water run-on or run-off to come into contact with significant sources of
pollutants or (2) roofs, covers, or other forms of appropriate protection to prevent storage piles
from exposure to storm water, and wind.
Additionally, storm water Pollution Prevention Plans must include a complete discussion of
measures taken to conform with the following applicable guidelines, other effective storm
water pollution prevention procedures, and applicable State rules, regulations, and guidelines:
• Liquid storage areas where storm water comes into contact with any equipment, tank,
container, or other vessel used for Section 313 water priority chemicals
• Material storage areas for Section 313 water priority chemicals other than liquids
• Truck and rail car loading or unloading areas for liquid Section 313 water priority
chemicals
• Areas where Section 313 water priority chemicals are transferred, processed, or
otherwise handled
• Discharges from areas covered by (1), (2), (3), or (4)
• Facility site runoff other than from areas covered by (1), (2), (3), or (4)
• Preventative maintenance and housekeeping
• Facility security
• Training
• Engineering certification.
The Plan may incorporate other plans that the facility may have already prepared for other
permits including Spill Prevention Control and Countermeasure (SPCC) Plans, or BMP
Programs.
Pollution Prevention Plan for Construction Activity
The Pollution Prevention Plan as required in the EPA storm water general permit for
construction activities must be prepared prior to submission of the NOI. An NOI for
construction activities commencing before October 1, 1992, and continuing after that date,
was due to be submitted by October 1, 1992. For construction activities commencing after
October 1, 1992, an NOI must be submitted at least 48 hours prior to commencement of
construction. The construction project must comply with the provisions of the Plan throughout
the construction period and must be signed by a responsible official such as the president,
vice president, or general partner. This Plan is to be kept at the construction facility during
the entire construction period and only has to be submitted for review when requested by
EPA.
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Chapter Eleven Storm Water
The Plan must contain a site description and a description of the measures and controls to
prevent or minimize pollution of storm water. Specifically, the inspector should verify that the
plan is current and that the description of the site includes the following:
• A description of the nature of the construction activity
• A sequence (schedule) of major construction activity
• An estimate of the total area of the site and of the area to be disturbed
• An estimate of the runoff coefficient of the site after construction is complete
• Any existing data on the quality of storm water discharge from the site
• The name of the receiving water
• Any information on the type of soils at the site
• A site map indicating drainage patterns and slopes after grading activities are
complete, areas of soil disturbance, the outline of the area to be disturbed, the location
of stabilization measures and controls, and surface waters at the discharge points.
Measures and controls must include three types of controls: erosion and sediment controls,
storm water management controls, and other controls. The inspector should verify that
appropriate measures and controls have been instituted as follows:
• Erosion and Sediment Controls — Disturbed areas where construction has
permanently or temporarily ceased must be stabilized (i.e., seeding, mulching, etc.)
within 14 days of the last disturbance or as soon as practicable in semi-arid and arid
areas. (Areas that will be redisturbed within 21 days do not have to be stabilized.)
Also, sites with common drainage locations that serve 10 or more disturbed acres must
install a sediment basin where it is attainable (where a basin is not attainable,
sediment traps, silt fence, or other equivalent measures must be installed). Sediment
basins must provide 3,600 cubic feet of storage per acre drained. Drainage locations
that serve less than 10 disturbed acres must install a sediment basin, a sediment trap,
or a silt fence along the down slope and side slope perimeter.
• Storm Water Management Controls — The permittee must consider installing
measures (storm water detention structures, infiltration measures, etc.) to control
pollutants after construction is complete. Velocity dissipation devices must be installed
in outfall channels to prevent erosion.
• Other Controls — The Plan must ensure that construction waste is not carried by storm
water into the receiving waters. Measures must be taken to prevent construction
vehicles from tracking soil off the construction site and to reduce the dust generation at
the construction site. The operator must comply with State and/or local sanitary sewer
or septic system regulations.
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Chapter Eleven Storm Water
Where State and local programs for sediment and erosion control, storm water management,
or site permits exist, the operator must certify that the Plan reflects and is in compliance with
the requirements of the applicable State or local program.
This Plan must also specify that operator personnel must inspect the construction site at least
once every 7 days and within 24 hours of a rainfall of 0.5 inches or more. Areas with sites
that have been finally stabilized or sites that are located in arid (i.e., less than 10 inches of
rain per year) or semi-arid (10 to 20 inches of rain per year) areas must be inspected at least
once a month. The inspector must prepare a report documenting his/her findings on the
conditions of the controls and stabilized areas.
Checklists relating to specific elements of the storm water Pollution Prevention Plan analysis
for construction activities are provided in Appendix M.
Specific inspector questions that may be appropriate at a given construction site to assess
activity-specific source control are presented in Appendix N. Site-specific BMPs for
construction activities are summarized in Figure 11-3.
Pollution Prevention Plan Implementation
Implementation of Pollution Prevention Plans require facilities to implement BMPs and train
employees on how to carry out the goals of the Plan. The inspector should evaluate any
implementation schedules developed by the facility for carrying out the Plan (e.g., deadlines
for putting improved housekeeping measures into practice). The inspector should also
determine whether appropriate individuals have been assigned to implement the specific
aspects of the Plan and whether these individuals are aware of the requirements of that
designation. If the Pollution Prevention Plan calls for the installation of structural controls, the
inspector should verify that the controls are in place and in good working order or that the
facility is on an appropriate schedule for construction of the structural control measures. The
inspector should also ensure that management approves of the implementation schedule and
strategy and is aware of the Pollution Prevention Plan process.
Additionally, employee training on the components and goals of the storm water Pollution
Prevention Plan must be performed at all levels of responsibility. The inspector should verify
that there are training programs and that the training focuses on spill prevention and
response, good housekeeping practices, and materials management. Additionally, facilities
that use or store EPCRA Section 313 water priority chemicals must conduct additional training
on preventative measures, pollution control laws and regulations, the facility's storm water
Pollution Prevention Plan, and features and operations of the facility that are designed to
minimize discharges of Section 313 water priority chemicals, particularly due to spills.
Typical Storm Water Discharge Permit Contents for Municipal Separate Storm Sewer Systems
Permits must be obtained for all discharges from large and medium municipal separate storm
sewer systems (and others as determined on a case-by-case basis). As mentioned above,
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Chapter Eleven Storm Water
the Director may either issue one system-wide permit covering all discharges from municipal
separate storm sewers or issue distinct permits for appropriate categories of discharges within
the system. EPA did not develop baseline general permits for storm water discharges from
municipal separate storm sewer systems, because of the differing nature of discharges from
municipal separate storm sewer systems in different parts of the country and the varying water
quality impacts of municipal storm sewer discharges on receiving waters. Based on permit
application requirements, these permits will likely address applicability, legal authority, source
identification, discharge characterization, management programs, control and impact
assessments, and financial commitments. The management program is considered to be the
most important requirement of a municipal separate storm sewer system permit. Existing
structural and non-structural prevention and control measures on discharges from municipal
separate storm sewers must be described in Part 1 of the permit application.
Storm Water Management Programs
The discussion that follows provides a general discussion of management program
requirements for municipal separate storm sewer systems. The Inspector will have to review
the facility's permit for specific considerations. Each municipal separate storm sewer system
covered by a permit must develop a management program, tailored to system-specific
conditions and designed to control the amount of pollutants in storm water discharges from
the system. The inspector should verify that these programs are being implemented as
appropriate to meet the current circumstances in the municipality. The permitting authority
has the right to review and request changes in the storm water management program.
Summaries of necessary components of these programs for municipal separate storm sewer
systems are provided below for both large- and medium-size municipalities.
Management Programs for Municipal Separate Storm Sewer Systems
In Part 2 of the permit application, the permittee, to meet the Maximum Extent Practicable
(MEP) standard, must identify additional prevention and control measures that will be
implemented during the life of the permit. EPA recognizes that it may not be possible to
identify all appropriate prevention and control permit conditions, but the process of identifying
components of a comprehensive prevention and/or control program should begin early.
Management programs must address pollutants from four types of sources: runoff from
commercial and residential areas, storm water runoff from industrial areas, runoff from
construction sites, and non-storm water discharges. Permits should address MEP control
measures for each of these components of the discharge. Discharges from some municipal
separate storm sewer systems may also contain pollutants from other sources, such as runoff
from land disposal activities. Where these other sources contribute significant amounts of
pollutants to a municipal separate storm sewer system, appropriate control measures should
be included. Also, permits should be written to reflect changing conditions that result from
program development and implementation and corresponding improvements in water quality.
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Chapter Eleven Storm Water
Priorities for addressing storm water discharges should be based on consideration of controls
that reduce pollutants to municipal separate storm sewer system discharges that are
associated with storm water from commercial and residential areas, illicit discharges and
illegal disposal, storm water from industrial areas, and runoff from construction sites. Permits
for different municipalities should place different emphasis on controlling different components
of discharges. For example, older municipalities will likely place more emphasis on cross-
connections than newer municipalities, who may focus more on construction activities.
Management programs must describe priorities for implementing controls and should be
based on the following four requirements:
1. Description of structural and source control measures that are to be implemented during
the life of the permit to reduce pollutants from runoff from commercial and residential
areas that is discharged from the municipal separate storm sewer system. The
description must be accompanied by an estimate of the expected reduction of pollutant
loads and a proposed schedule for implementing such controls. At a minimum, the
description should include:
• Maintenance activities and a maintenance schedule for structural controls.
• Planning procedures to develop, implement, and enforce controls to reduce discharges
from areas of new development and significant redevelopment after construction is
complete.
• Practices for operating and maintaining public streets, roads, etc., and procedures for
reducing the impact as a result of deicing activities.
• Procedures to ensure that flood management projects assess the impacts on the water
quality of receiving water bodies and that existing structural flood control devices have
been evaluated if retrofitting is possible for additional pollutant removal.
• Program, including inspections and procedures to establish and implement controls, to
monitor pollutants in runoff from operating or closed municipal landfills or other
treatment, storage, or disposal facilities for municipal waste.
• Program to reduce to the MEP pollutants in discharges from the application of
pesticides, herbicides, and fertilizers. This may include educational activities, permits,
certifications, and other measures for commercial applicators and distributors, and
controls for application in public right-of-ways and at municipal facilities.
2. Description of a program, including a schedule, to detect and remove (or to require the
discharger to the municipal separate storm sewer system to obtain a separate NPDES
permit for) illicit discharges and improper disposal into the storm sewer. At a minimum,
the proposed program should include:
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Chapter Eleven Storm Water
• Program, including inspections, to implement and enforce an ordinance, order, or
similar means to prevent illicit discharges to the municipal separate storm sewer
system
• Procedures to conduct on-going field screening activities during the life of the permit
• Procedures to be followed to investigate portions of the separate storm sewer system
that indicate a reasonable potential of containing illicit discharges or other sources of
non-storm water
• Procedures to prevent, contain, and respond to spills that may discharge into the
municipal separate storm sewer
• Program to promote, publicize,'and facilitate public reporting of the presence of illicit
discharges or water quality impacts associated with discharges from municipal
separate storm sewer systems
• Educational activities, public information activities, and other appropriate activities to
facilitate the proper management and disposal of used oil and toxic materials
• Controls to limit infiltration of seepage from municipal sanitary sewers to municipal
separate storm sewer systems.
3. Description of a program to monitor and control pollutants in storm water discharges to
municipal systems from municipal landfills; hazardous waste treatment, disposal, and
recovery facilities; industrial facilities that are subject to section 313 of SARA Title III; and
industrial facilities that the municipal permit applicant determines are contributing a
substantial loading to the municipal separate storm sewer system. The program should
include:
• Priorities and procedures for inspections and establishing and implementing control
measures for such discharges
• Monitoring program for storm water discharges associated with, industrial facilities
identified in 3., to be implemented during the term of the permit, including the
submission of quantitative data.
4. Description of a program to implement and maintain structural and non-structural best
management practices to reduce pollutants in storm water runoff from construction sites
to the municipal separate storm sewer system. This program should include:
• Procedures for site planning that incorporate consideration of potential water quality
impacts
• Requirements for non-structural and structural best management practices
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Chapter Eleven Storm Water
Procedures for identifying priorities for inspecting sites and enforcing control measures
that consider the nature of the construction activity, the topography, and the
characteristics of soils and receiving water quality
Appropriate educational and training measures for construction site operators.
Management Program Implementation
Implementation of management programs requires facilities to implement a variety of control
measures, programs, procedures, and training of various individuals on how to carry out the
goals of the program. The inspector should evaluate any implementation schedules
developed by the municipality for carrying out the program and determine whether appropriate
individuals have been assigned to implement the specific aspects of the program and if these
individuals are aware of the requirements of that designation. If the program calls for the
installation or maintenance of structural controls, the inspector should verify that the controls
are in place and in good working order or that the facility is on an appropriate schedule for
construction of the structural control measures.
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Chapter Eleven Storm Water
Figure 11-2.
Site-Specific Industrial Storm Water BMPs
Flow Diversion Practices
Flow diversion is practiced to channel storm water away from industrial activities to prevent storm water
contact with industrial pollutants. Additionally, flow diversion may be used to channel polluted storm water
directly to a treatment facility.
Flow diversion practices include storm water conveyances (e.g., channels, gutters, drains, and sewers),
diversion dikes, and graded areas and pavement.
Exposure Minimization Practices
Exposure minimization is practiced to eliminate or minimize the contact of storm water with industrial
activities and its pollutants. If contact of storm water with pollutants is minimized, the costs of collecting
and treating and storm water and the environmental releases that occur will be reduced.
Exposure minimization practices include containment diking, curbing, drip pans, collection basins, sumps,
covering, vehicle positioning, and loading and unloading by air pressure or vacuum.
Mitigative Practices
Mitigation is practiced to clean up or recover a substance (i.e., potential pollutant) before it comes in
contact with storm water. Mitigation is a second step after pollution prevention.
Mitigative practices include sweeping, shoveling, excavation practices, vacuum and pump systems,
sorbents, and gelling agents.
Other Preventative Practices
Other preventative practices can be taken to limit/prevent the exposure of storm water to industrial
activities. These practices may be either structural or procedural measures taken to reduce/eliminate
exposure.
Other preventative practices include preventative monitoring practices, dust control (land disturbances and
demolition areas), dust control (industrial activities), signs and labels, security, area control procedures,
and vehicle washing.
Sediment and Erosion Prevention Practices
Sediment and erosion prevention can be accomplished using seven general practices: vegetate the site,
minimize soil exposure to storm water, keep runoff from disturbed areas, stabilize disturbed soils, slow
down runoff, provide drainage ways for runoff, and remove sediment from the runoff before it leaves the
site.
Sediment and erosion prevention practices include vegetative practices, structural erosion prevention, and
sediment control practices.
Infiltration Practices
Infiltration practices are measures that increase the infiltration of storm water runoff into the ground through
the use of very porous soils. Infiltration practices may also reduce the velocity of storm water, thereby
minimizing erosion potential of the runoff.
Infiltration practices include vegetated filter strips, grassed swales, level spreaders, infiltration trenches,
and porous pavements/concrete grids and modular pavements.
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Chapter Eleven Storm Water
Figure 11-3.
Site-Specific Construction Storm Water BMPs
Stabilization Practices
Stabilization is practiced to control erosion due to unvegetated areas. Stabilization reduces
erosion potential in four ways: (1) by shielding the soil surface from direct erosive impact
of raindrops, (2) by improving the soil's water storage porosity and capacity, (3) by slowing
the runoff and allowing the sediment to drop out or deposit; and (4) by physically holding
the soil in place with plant roots. Vegetative (e.g., grasses, trees, or shrubs) covers are the
most common type of stabilization.
Stabilization practices include temporary seeding, mulching, geotextiles, chemical
stabilization, permanent seeding and planting, buffer zones, preservation of natural
vegetation, sod stabilization, stream bank stabilization, soil retaining measures, and dust
control.
Structural Erosion and Sediment Control Practices
Structural erosion and sediment control diverts storm water flows away from exposed
areas, conveys runoff, prevents sediments from moving offsite, and reduces the erosive
forces of runoff waters.
Structural erosion and sediment control practices include earth dikes, drainage swales,
interceptor dikes and swales, temporary stream crossing, temporary storm drain diversion,
pipe slope drains, subsurface drains, silt fence, gravel or stone filter berm, storm drain inlet
protection, sediment trap, temporary sediment basin, outlet protection, check dams, surface
roughening, and gradient terraces.
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11. STORM WATER
C. Sampling and Inspection
Considerations
Storm Water Pollutant Sources
Storm water contamination associated with industrial activities depends on a variety of factors,
including the operations of the facility, the nature of precipitation, and the imperviousness of
the soils. Storm water can pick up pollutants as it drains from the land, although other
sources such as illicit connections, spills, and other improperly dumped materials may
increase the pollutant loads discharged from storm sewers. The specific sources of pollutants
in storm water vary depending on the nature of industry operations and specific facility
features. Storm water discharges from industrial facilities may also contain excess toxics and
conventional pollutant loadings where poor housekeeping and materials management activities
are practiced.
One of the major efforts to evaluate storm water runoff was the National Urban Runoff
Program (NURP), conducted between 1978 and 1983. This study evaluated storm water
runoff from commercial and residential areas. The NURP study found that, on average, total
suspended solids concentrations in storm water runoff are an order of magnitude greater than
those in typical discharges from a sewage treatment plant providing secondary treatment.
Additionally, COD was found to be comparable to that of a secondary treatment plant.
Sampling conducted for the NURP study also detected 77 priority pollutants in storm water
discharges from residential, commercial, and light industrial lands. While NURP did not
evaluate oil and grease, other studies have shown hydrocarbon levels to be in the 2 to 10
mg/l range and have been shown to accumulate in bottom sediments and adversely affect
benthic organisms.
Other studies have also shown that many storm sewers contain illicit non-storm water
discharges, in which large amounts of waste are disposed of improperly. For example, one
study found that 14 percent of the buildings in one area had improper storm drain connections
with a much higher rate of 60 percent for automobile-related businesses and light industrial
facilities. While some of these connections were illegal or improper plumbing, a majority of
these connections were approved at the time they were built, but have since become unlawful
discharges.
Six activities have been identified as major potential sources of pollutants in sto^m water
discharges associated with industrial activity: (1) loading or unloading of dry bulk materials or
liquids; (2) outdoor storage of raw materials or products; (3) outdoor process activities; (4)
dust or paniculate generating processes; (5) illicit connections or inappropriate management
practices; and (6) waste disposal practices. More detailed discussion of these operations
follows.
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Chapter Eleven Storm Water
Loading or unloading of dry bulk materials or liquids: These operations are typically
performed along facility access roads and rail lines and at loading/unloading docks and
terminals. Activities include pumping liquids or gases from truck or rail car to a storage facility
or vice versa, pneumatic transfer of dry powder chemicals to or from the transportation
vehicle, transfer by mechanical conveyor, and transfer of bags, boxes, drums, totes, or other
containers from vehicles. Material spills and incidental material losses may discharge directly
to the storm drain or may accumulate in soils or on surfaces and be washed away during a
storm or facility washdown.
Outdoor storage of raw materials or products: This includes the storage of fuels, raw
materials, by-products, intermediates, final products, and waste residuals. Storage practices
include using containers such as drums or tanks, platforms, bins, silos, boxes, or piles. When
these areas are exposed to rain and/or runoff, solid material and other pollutants may wash
off or dissolve into solution and be carried away.
Outdoor process activities: This includes certain types of manufacturing and commercial
operations or land-disturbing operations. Activities such as equipment maintenance, timber
processing, rock crushing, and concrete mixing often occur outdoors. Processing operations
can result in spills or product loss to the drainage system or creation of dusts or mists that
can be deposited locally. Activities such as construction and mining cause large land
disturbances. Disturbed land can result in soil loss and other pollutant loadings associated
with increased runoff. Also, many facilities apply chemicals such as herbicides, pesticides,
and fertilizer on the property regardless of whether process activities are conducted indoors or
outdoors.
Dust or particulate generating processes: Industrial activities with stack emissions or process
dusts can cause localized atmospheric deposition of pollutants that are washed away during
storms. Heavy manufacturing operations such as smelting, mining, and cement manufacturing
generate significant levels of dust. In addition, facilities, such as bakeries, can generate
significant particulate emissions from baking oven exhausts.
Illicit connections or inappropriate management practices: Illicit connections tend to be found
more often at older facilities as well as at facilities that use high volumes of process water or
dispose of significant volumes of liquid waste. Pollutants from non-storm water discharges to
the storm sewer are usually a result of improper connections, improper dumping, and the
belief that absence of visible solids in a discharge is equivalent to the absence of pollution.
Illicit connections are often associated with floor drains connected to storm sewers. Floor
drains can be the source of non-storm water discharges such as heat exchanger condensate,
facility washdown, and cooling waters. These discharges may be either intentional, with the
discharger believing that the discharge does not contain pollutants, or inadvertent, if the
operator is unaware that the floor drain is connected to the storm sewer.
Waste disposal practices: These activities include temporary storage of waste materials,
operating landfills, waste piles, and land application sites. Outdoor waste treatment practices,
such as waste pumping, wastewater treatment chemical addition, mixing, aeration,
clarification, and solids dewatering, can contribute pollutant loadings to storm water.
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Chapter Eleven Storm Water
Storm Water Sampling Considerations
In addition to the applicable conditions described in Chapters Five through Eight on Sampling,
Flow Measurement, Toxicity, and Laboratory Procedures and Quality Assurance, the inspector
also must verify storm water specific sampling considerations. Sampling personnel must be
especially flexible when attempting to collect storm water samples. Whether the inspector
plans to sample a facility's storm water discharge or evaluate a facility's storm water discharge
sampling program, he/she may need to adjust for any of the following:
• No rainfall
• Hazardous weather conditions
• Non-representative storm event (i.e., not within 50 percent of the volume and duration
for the average storm event for that area)
• Duration between the previous measurable storm event and the storm event to be
sampled of less than 72 hours
• Form of precipitation (i.e., snow melt or rainfall)
• Accessibility of sampling locations.
These conditions make sampling of storm water very difficult. When any of the situations
described above arises, the inspector should determine the potential effects of these
conditions on the sampling event and use his/her best judgment on proceeding. The decision
may be to go on with the sampling, wait till a later date, or sample at a location that may not
be the most appropriate sampling location. An inspector's review of a facility's storm water
sampling data may require similar decisions to be made.
EPA's general permit established monitoring requirements for only certain classes of industrial
sites. These requirements are identified in Appendix O. Permitting authorities are authorized
to include more stringent monitoring conditions; therefore, the inspector should review the
facility's permit to identify the site-specific requirements.
The storm water regulations specify the nature of the storm event to be sampled and the
sample collection methodology:
• All samples must be collected from a storm event greater than p.1 inches in
magnitude.
• The storm event must be at least 72 hours after the previously measurable storm event
(greater than 0.1 inches).
• Where feasible, the variance in the duration of the event and the total rainfall of the
event should not exceed 50 percent from the average or median rainfall event in that
area. A map of the United States with the rain zones and typical values of annual
storm events is provided as Appendix P.
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Chapter Eleven Storm Water
• Data must be reported for both a grab and composite sample (except for discharges
from holding ponds or impoundments with a retention time of greater than 24 hours; for
those discharges, results for a grab sample must be reported).
• The grab sample must be taken within the first 30 minutes of the discharge (if
impracticable, the grab can be collected in the first hour with a description of why a
grab sample in the first 30 minutes was not possible).
• Composite samples may be either time- or flow-weighted.
• Composite samples may be collected with an automatic sampler or as a combination
of a minimum of three aliquots taken in each hour of discharge for the entire discharge
or for the first three hours of the discharge, with each aliquot being separated by a
minimum of 15 minutes.
EPA's general permit requires retention of monitoring records for 6 years, since many facilities
will not be required to submit the results of monitoring to the permitting authority. In addition,
Pollution Prevention Plans must be kept for the life of the permit.
Sample types are consistent with those presented in 40 CFR Part 136, i.e., grab samples
collected for pH, temperature, cyanide, phenols, total residual chlorine, oil and grease, fecal
coliform, and fecal streptococcus and 24-hour composites collected for all other pollutants. An
exception to this is if a facility is sampling storm water from an impoundment or holding pond
with a retention time of more than 24 hours. In these cases, one grab sample can be
collected and analyzed for all parameters.
One unique aspect of the storm water regulations is that a facility can demonstrate
substantially identical outfalls or representative outfalls where it has two or more outfalls with
similar effluents. In the case of group applications, the substantially identical outfall petition
was to be submitted to EPA. Where the petition request was approved, the permittee only
has to sample one of the substantially identical outfalls and report that the quantitative data
also apply to the substantially identical outfalls. For facilities subject to EPA's general permit,
the facility has to document why a given outfall is representative of more than one outfall and
maintain this documentation on site. When assessing the applicability of substantially identical
outfalls or representative outfalls, the inspector should verify that the outfalls receive storm
water discharges from substantially identical or representative:
• Industrial activities and processes
• Significant materials that may be exposed to storm water
• Storm water management practices and material management practices
• Flows, as determined by the estimated runoff coefficient and approximate drainage
area at each outfall.
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Chapter Eleven Storm Water
Flow Measurement Considerations
The storm water regulations allow for storm water flow to be measured or estimated. Flow
measurement devices may either be permanent or portable devices. A discussion of flow
measurement techniques and inspector procedures is provided in Chapter Six. In certain
instances, a facility may estimate the storm water flow rate. EPA's Storm Water Sampling
Guidance Document (July 1992) outlines the four most common methods for estimating storm
water flow rate: the runoff coefficient method, the float method, the slope and depth method,
and the bucket and stopwatch method.
The runoff coefficient method is the least accurate method for estimating flows and should
only be used if all other measurement and estimation techniques are inappropriate. Runoff
coefficients are documented estimates of the fraction of rainfall that will run off from the
drainage area taking into account the part that infiltrates the ground. Commonly used runoff
coefficients are presented in Appendix Q. For a site with multiple types of surface areas (e.g.,
flat lawns, brick streets, and light industrial areas) the average runoff coefficient should be
determined by averaging the runoff coefficients over the entire site, taking into account the
area of each of the different surface areas.
The float method is appropriate where the flow is easily accessible and open; the velocity is
determined by measuring the time it takes a float to travel between two points, and the area is
determined by measuring the depth and width of the flow.
The slope and depth method, based on Manning's Equation, is appropriate for flow from a
pipe or ditch where the slope of the conveyance is known and the flow does not totally fill the
ditch or pipe from which it is flowing. To use this method, the depth of the flow in the middle
of the pipe or ditch is recorded, as is the inside diameter of the pipe or the width of the ditch.
The bucket and stopwatch method is appropriate where the flow is from a pipe or ditch, free
flowing, and small enough to be captured in a bucket (or similar container). This method is
rarely suitable for storm water flow measurement because of the impracticality of the
procedure.
Inspecting for Illicit Connections
Illicit connections are point source discharges of pollutants to separate storm sewer systems
that are not composed entirely of storm water and that are not authorized by an NPDES
permit. There are two types of illicit connections: pronounced (direct hookups to the sewer
system) and subtle (indirect, intermittent, usually without piping).
The first thing that an inspector should evaluate is the facility's non-storm water discharge
certification. This certification, required as a component of the permit application, should
include a description of the testing methods used, the date of any testing, and the onsite
drainage points that were directly observed during the tests.
The storm water regulations do specify that certain "non-storm water discharges" may be
authorized by a storm water permit, provided the measures and controls for non-storm water
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Chapter Eleven Storm Water
discharges are included in the facility's Pollution Prevention Plan. Authorized non-storm water
discharges include:
• Discharges from firefighting activities
• Fire hydrant flushings
• Potable water sources including waterline flushings
• Irrigation drainage
• Lawn watering
• Routine external building washdown that does not use detergents or other compounds
• Pavement washwaters where spills or leaks of toxic or hazardous materials have not
occurred (unless all spilled material has been removed) and where detergents are not
used
• Air conditioning condensate
• Springs
• Uncontaminated ground water
• Foundation or footing drains where flows are not contaminated with process materials
such as solvents.
Inspectors can evaluate facilities for illicit connections using a two-step process. First,
inspectors should screen the facility for indications of possible illicit connections. If indications
exist, the inspector needs to investigate for identification of actual illicit connections.
Prior to conducting an inspection, general facility and locational maps should be reviewed for
potential areas of concern. Site maps required in the Pollution Prevention Plan, topographic
maps (indicating drainage patterns), and sewer maps are three of the better sources,
although, depending on the site, additional maps may be of assistance. Considerations during
the mapping review include the density of industrial activity in the area, the type of industrial
activity (and the likelihood of that industry having illicit connections), and the proximity of the
industrial facility to the storm water outfall.
Upon arrival at the facility, the inspector should conduct a tour to detect indications of possible
illicit connections. Indications may include the following:
• Dry weather flows
• Odors, residues, color, floatables, or other noticeable properties in the outfall
• Affected vegetation in the area of the outfall
• Structural damage (e.g., cracked cement, peeling paint, corroded metal).
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Chapter Eleven Storm Water
If any of these conditions exist, the inspector should consider performing field analytical
testing on the discharge to ascertain the potential source of the discharge. Conductivity and
pH are two tests that are inexpensive and easy to perform at the outfall location and can be
key indicators of non-storm water discharges.
Upon identification of a potential illicit connection, the inspector should evaluate the flow
pattern of the discharge. Continuous dry weather flows are a good indication of an illicit
discharge, but may also be indicative of infiltration into the collection system. Also, the
inspector should verify whether or not any NPDES-permitted flows are discharged to the
outfall in question. Intermittent dry weather flows are probably not due to infiltration,
especially where the flows vary considerably over a short period of time. The inspector
should plan on possibly returning to the site to further investigate dry weather flows.
After evaluating the flow pattern of the discharge, the inspector should analyze all available
chemical and physical data. All discernible properties of the discharge should be noted.
Inspectors should be aware that discharges from illicit connections are not necessarily highly
polluted. Sources such as non-contact cooling water or boiler blowdown may appear
extremely clear and clean. The inspector should not consider these "clean" streams to be
innocuous. For example, non-contact cooling water, which supposedly does not come in
contact with any pollutants, other than heat, may be contaminated from leaking heat
exchanger jackets or may be treated with anti-scaling chemicals, anti-oxidants, or biological
inhibitors.
After characterizing the discharge, the inspector should try to correlate this water with
industrial activities that may be contributing this discharge. Consideration should be given to
chemical loading/unloading areas, cooling waters, process waters, pronounced illicit
connections, and the age of the facility (i.e., older facilities are more likely to have illicit
connections).
Inspectors prepared to investigate for possible illicit connections should have the following
equipment available:
Field test kit
pH meter and buffer solution
Conductivity meter and buffer solution
Automatic sampler
Instant camera and film
Sample collection bottles
Crowbar
Flashlight/mirror
Dye tracer (e.g., fluorescein)
Topographic and sewer maps
Cooler (with ice)
Stakes
Personal safety equipment.
To evaluate potential illicit connections, the inspector should investigate manholes, catch
basins, storm water runoff direction, material storage areas, cleanliness of loading/unloading
areas, spill control, nature and condition of waste management areas, floor drains, and
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Chapter Eleven Storm Water
storage areas. Processes or equipment for which the facility does not know the discharge
destination should be considered to have a high potential as an illicit connection. Where the
inspector believes that a process or piece of equipment may be the source of an illicit
connection, dye tracer testing (using a fluorescent dye such as fluorescein) may be
appropriate. If the dye is visible at the outfall, then an illicit connection has been identified.
Failure to see the dye at the outfall is not necessarily indicative of the lack of an illicit
connection. Decrepit sewer systems may prevent the dye from appearing at the outfall. In
these instances, a sewer system investigation may be necessary.
Upon identification of an illicit connection, the permittee must do one of the following:
• Redirect the discharge into an approved outfall
• Submit a NPDES permit application (Forms 1 and 2C) for discharge
• Reconnect to the sanitary sewer system
• Cease the discharge
• Recycle the water.
For additional information on identifying illicit connections, refer to EPA investigations of
Inappropriate Pollutant Entries Into Storm Drainage Systems, A User's Guide (January 1993).
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11. STORM WATER
D. References
API. August 1989. "Suggested Procedure for Development of Spill Prevention Control and
Countermeasure Plans," American Petroleum Institute Bulletin D16, Second Edition.
APWA. 19891. Urban Stormwater Management, Special Report No. 49. American Public
Works Association Research Foundation.
Arapahoe County. April 8, 1988. "Erosion Control Standards." prepared by Kiowa
Engineering Corporation.
Commonwealth of Pennsylvania. April 1990. Erosion and Sediment Pollution Control
Program Manual, Pennsylvania Department of Environmental Resources, Bureau of Soil and
Water Conservation.
Commonwealth of Virginia. 1980. Virginia Erosion and Sediment Control Handbook, Virginia
Department of Conservation and Historical Preservation, Division of Soil and Water
Conservation, Second Edition.
County of Fairfax. 1990 and 1987 Editions. "Check List For Erosion and Sediment Control
Fairfax County, Virginia."
MWCOG. July 1987. Controlling Urban Runoff: A Practical Manual for Planning and
Designing Urban BMPs," Department of Environmental Programs, Metropolitan Washington
Council of Governments.
Northern Virginia Planning District Commission. August 1987. BMP Handbook for the
Occoquan Watershed, prepared for Occoquan Basin Nonpoint Pollution Management
Program.
Salt Institute. 1987. The Salt Storage Handbook, A Practical Guide for Storing and Handling
Deicing Salt. Alexandria, Virginia.
Santa Clara Valley Nonpoint Source Pollution Control Program. Automotive-Related
Industries, BMPs for Industrial Sanitary Sewer Discharges and Storm Water Pollution Control.
State of Maryland. April 1983. 1983 Maryland Standards and Specifications for Soil and
Erosion and Sediment Control. Maryland Water Resources Administration, Soil Conservation
Service, and State Soil Conservation Committee.
State of North Carolina. September 1, 1988. Erosion and Sediment control Planning and
Design Manual. North Carolina Sedimentation Control Commission, Department of Natural
Resources and Community Development, and Agricultural Extension Service.
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Chapter Eleven Storm Water
State of Wisconsin. June 1990. Wisconsin Construction Site Best Management Practice
Handbook. Wisconsin Department of Natural Resources, Bureau of Water Resources
Management, Nonpoint Source and Land Management Section.
Thron, H. and O.J. Rogashewski. 1982. "Useful Tools for Cleaning Up." Hazardous Material
& Spills Conference.
U.S. Environmental Protection Agency. CZARA NPS Guidance.
U.S. Environmental Protection Agency. December 1991. "Draft - A Current Assessment of
Urban Best Management Practices. Techniques for Reducing Non-point Source Pollution in
the Coastal Zone." EPA Office of Wetlands, Oceans and Watersheds, prepared by
Metropolitan Washington Council of Governments.
U.S. Environmental Protection Agency. June 26, 1991. "Draft Construction Site Stormwater
Discharge Control, An Inventory of Current Practices." EPA Office of Water Enforcement and
Permits, prepared by Kamber Engineering.
U.S. Environmental Protection Agency. June 1987. "Draft Report on Best Management
Practices for the Control of Storm Water From Urbanized Areas." Science Applications
International Corporation.
U.S. Environmental Protection Agency. April 20, 1990. "Draft Sediment and Erosion Control,
An Inventory of Current Practices." EPA Office of Water Enforcement and Permits, prepared
by Kamber Engineering.
U.S. Environmental Protection Agency. April 1991. Guidance Manual for the Preparation of
NPDES Permit Applications for Discharges Associated with Industrial Activity. EPA-505/8-91 -
002.
U.S. Environmental Protection Agency. April 1991. Guidance Manual for the Preparation of
NPDES Permit Applications for Discharges From Municipal Separate Storm Water Systems.
EPA-505/8-91-003A.
U.S. Environmental Protection Agency. January 1993. "Investigation of Inappropriate
Pollutant Entries into Storm Drainage Systems, A User's Guide. EPA/600/R-92/238.
U.S. Environmental Protection Agency. December 1979. NPDES Best Management
Practices Guidance Document. Industrial Environmental Research Laboratory, Cincinnati,
Ohio, prepared by Hydroscience, Inc., EPA 600/9-79-0451.
U.S. Environmental Protection Agency. March 1992. NPDES Storm Water Program Question
and Answer Document. Office of Wastewater Enforcement and Compliance, Permits Division.
U.S. Environmental Protection Agency. July 1993. NPDES Storm Water Program Question
and Answer Document: Volume II. Office of Wastewater Enforcement and Compliance,
Permits Division.
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Chapter Eleven Storm Water
U.S. Environmental Protection Agency. October 1989. Pollution Prevention in Printing and
Allied Industries: Saving Money Through Pollution Prevention. Office of Research and
Development, Pollution Prevention Office.
U.S. Environmental Protection Agency. January 1992. Pollution Prevention Training
Opportunities in 1992. EPA/560/8-92-002. (A comprehensive listing of pollution prevention
resources, documents, courses, and programs, including names and phone numbers, is
contained in a new annual EPA publication. Copies of this document may be obtained by
calling the PPIC/PIES support number at (703) 821-4800.)
U.S. Environmental Protection Agency. October 1973. Process, Procedure, and Methods to
Control Pollution Resulting from All Construction Activity. EPA Office of Air and Water
Programs, PB-257-318.
U.S. Environmental Protection Agency. July 1991. Staff Analysis. Storm Water Section.
U.S. Environmental Protection Agency. September 1992. Storm Water Management for
Industrial Activities, Developing Pollution Prevention Plans and Best Management Practices.
EPA-832-R-92-006,
U.S. Environmental Protection Agency. September 1992. Storm Water Management for
Construction Activities, Developing Pollution Prevention Plans and Best Management
Practices. EPA-832-R-92-005.
U.S. Environmental Protection Agency. July 1992. Storm Water Sampling Guidance
Document. EPA 833-B-92-001.
U.S. Environmental Protection Agency. July 1988. Waste Minimization Opportunity
Assessment Manual. Hazardous Waste Engineering Research Laboratory.
Washington State. January 23, 1992. "Draft Stormwater Management Manual for the Puget
Sound Basin." Washington State Department of Ecology.
Washington State. July 29, 1991. "Standards for Storm Water Management for the Puget
SoUnd Basin," Chapter 173-275 WAC. Washington State Department of Ecology.
Regulations/Notices
Federal Register (55 FR 47990). November 16, 1990. National Pollutant Discharge
Elimination System (NPDES) Permit Application Requirements for Storm Water Discharges -
Final Rule.
Federal Register (55 FR 12098). March 21, 1991. Application Deadline for Group
Applications — Final Rule; Application Deadline for Individual Applications — Proposed Rule.
Federal Register (56 FR 40948). August 16, 1991. NPDES General Permits and Reporting
Requirements for Storm Water Discharges Associated With Industrial Activity — Proposed
Rule.
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Chapter Eleven Storm Water
Federal Register (56 FR 50548). November 5, 1991. Application Deadline; Final Rule and
Proposed Rule.
Federal Register (57 FR 11394). April 2, 1992. Application Deadlines, General Permit
Requirements and Reporting Requirements, Final Rule.
Federal Register (57 FR 41176). September 9, 1992. Final NPDES General Permits for
Storm Water Discharges from Construction Sites; Notice.
Federal Register (57 FR 44412). September 25, 1992. Final NPDES General Permits for
Storm Water Discharges from Construction Sites; Notice.
Federal Register (57 FR 41236). September 9, 1992. Final NPDES General Permits for
Storm Water Associated with Industrial Activity; Notice.
Federal Register (57 FR 44438). September 25, 1992. Final NPDES General Permits for
Storm Water Associated with Industrial Activity; Notice.
Federal Register (57 FR 41344). September 9, 1992. National Pollutant Discharge
Elimination System, Request for Comment on Alternative Approaches for Phase II Storm
Water Program; Proposed Rule.
Federal Register (57 FR 60444). December 18, 1992. Permit Issuance and Permit
Compliance Deadlines for Phase I Discharges; Final Rule.
Federal Register (58 FR 19427). April 14, 1993. NPDES General Permit for Storm Water
Discharges Associated with Industrial Activity Located in the Commonwealth of Puerto Rico;
Notice.
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12. COMBINED SEWER OVERFLOWS
Contents Page
A. Review of the CSO Policy
B. CSO Inspection Procedures
Preparation 12-5
Onsite Records Review 12-7
Interviews 12-7
Facility Site Inspection 12-8
C. References and Checklist
References 12-11
List of Tables
12-1. Nine Minimum CSO Controls 12-3
12-2. Elements of the Long-Term CSO Control Plan 12-3
12-3. CSO Records 12-9
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Chapter Twelve Contents
*** Kirvrce ***
NOTES
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12. COMBINED SEWER OVERFLOWS
A. Review of the CSO Policy
About 1,100 communities in the U.S. have sewer collection systems that are combined
sanitary and storm sewer systems. In certain instances these sewers overflow, such as
during rain events. The Combined Sewer Overflows (CSOs) consist of mixtures of domestic
sewage, industrial and commercial wastewaters, inflow/infiltration, and storm water runoff.
EPA estimates that there are as many as 15,000 CSO discharge points nationwide. CSOs
are considered as point sources of pollution to surface waters. Thus, they are covered under
the Clean Water Act (CWA) and are subject to the National Pollutant Discharge Elimination
System (NPDES) permit program. However, until recently, CSOs received less than full
attention in terms of national rulemaking or specific CSO permit conditions in individual
NPDES permits. There are no national Best Available Technology/Best Control Technology
(BAT/BCT) effluent guidelines and limitations for CSOs. Unlike Publicly Owned Treatment
Works (POTWs), CSOs are not subject to secondary treatment requirements.
Two of the largest problems associated with CSO pollution control are (1) the complexity and
variability of CSO discharges and (2) the potentially high costs of their abatement. The types,
concentrations, and volumes of pollutants and their impacts on receiving waters vary widely
from system to system, and within a system, they vary from one storm event to the next.
Additionally, it can be difficult to determine the impact of CSOs on receiving water quality
because, in most cases, such data have not been collected. Water Quality Standards
(WQSs) are mostly based upon dry weather flows, and water quality and benthic data are
collected during non-storm periods, which means impacts of CSOs on streams may not be
completely understood. Impacts are often determined by environmental measurements such
as beach closings, number of complaints regarding floatables, or poor aesthetics.
EPA's 1994 CSO Control Policy (59 FR 18688) has developed an approach to permitting
CSOs that is designed to abate CSO pollution problems while still retaining the flexibility
necessary to deal with each CSO situation on a site-specific basis. The Policy's strategy
encourages permittees with CSOs to:
• Implement technology-based CSO controls as soon as possible but no later than
January 1, 1997. The policy describes nine CSO control measures that may be
considered minimum BAT/BCT, based on the permitting authority's best professional
judgment.
• Develop a Long-Term CSO Control Plan (LTCP) generally within 2 years after the date
of the NPDES permit provision, Section 308 information request, or enforcement action
requiring the permittee to develop the plan. The policy describes the minimum
elements which the LTCP should address.
• Implement the LTCP according to a schedule that allows the permittee to phase in
implementation based on the relative importance of and adverse impacts upon WQS
and the permittee's financial capability and its previous efforts to control CSOs.
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Chapter Twelve Combined Sewer Overflows
• Implement a post-construction compliance monitoring program.
The permitting and enforcement authorities are expected to take enforcement action against
dry weather CSO discharges.
As outlined in the CSO Policy, the nine minimum CSO controls are listed in Table 12-1 and
the elements of the LTCP are listed in Table 12-2. The major approach to CSO control,
outlined in EPA's CSO Control Policy, is to:
• Eliminate CSOs to sensitive areas wherever possible (where not possible, provide
treatment).
• Coordinate the review and revision of water quality standards with development of
long-term CSO control plans.
• Evaluate a reasonable range of alternatives that could achieve the necessary level of
control/treatment, and select the controls to be implemented based on cost/
performance evaluations.
• Develop an implementation schedule based on the relative impacts on WQS and
designated uses, on the priority of projects identified in the LTCP, and on the
permittee's financial capability.
• Maximize treatment of wet weather flows at the POTW.
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Chapter Twelve Combined Sewer Overflows
Table 12-1.
Nine Minimum CSO Controls
• Proper operation and regular maintenance programs for the sewer system and the
CSOs
• Maximum use of the collection system for storage
• Review and modification of pretreatment requirements to ensure that CSO impacts are
minimized
• Maximization of flow to the POTW for treatment
• Prohibition of CSOs during dry weather
• Control of solid and floatable materials in CSOs
• Establishment of pollution prevention programs
• Public notification to ensure that the public receives adequate notification of CSO
occurrences and CSO impacts
• Monitoring to effectively characterize CSO impacts and the efficacy of CSO controls
Table 12-2.
Elements of the Long-Term CSO Control Plan
• Characterization, monitoring, and modeling of the combined sewer system
• Public participation
• Consideration of sensitive areas
• Evaluation of alternatives
• Cost/performance considerations
• Operational plan
• Maximizing treatment at the existing POTW treatment plant
• Implementation schedule
• Post-construction compliance monitoring program
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Chapter Twelve Combined Sewer Overflows
*** NOTES ***
12-4
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12. COMBINED SEWER OVERFLOWS
B. CSO Inspection Procedures
Each municipality's specific CSO requirements will be contained in an NPDES permit, an
enforcement order, a consent decree, or other enforceable documents. The CSO conditions
will be specific to that permittee. The compliance inspector will be faced with obtaining
information to determine compliance in the following areas:
• Ensuring that CSOs do not occur during dry weather
• Implementation of the nine minimum CSO controls
• Adherence to schedule for development and submission of a Long-Term CSO Control
Plan, including any interim deliverables
• Adherence to schedule for implementation of the CSO controls selected from the Long-
Term CSO Control Plan
• Narrative, performance-based or numerical, water quality-based effluent limitations
• Monitoring program, including baseline information on frequency, duration, and impacts
of CSOs
• Elimination or relocation of overflows from sensitive areas.
Preparation
Requirements for CSO control can be found in two separate documents: the permit and
enforcement orders, such as Administrative Orders or Judicial Orders, or Consent Decrees.
Inspectors should review the permit and other enforceable mechanisms issued to the
permittee. The inspector may find CSO conditions that address:
• Requirements to implement and document implementation of technology-based
controls (i.e., nine minimum controls) by the date specified in the permit or enforceable
mechanism.
• Requirement to submit a report documenting the implementation of the nine minimum
controls; the report will usually be required within 2 years of permit issuance.
• Requirements for the development, submission, and implementation of the Long-Term
CSO Control Plan. Where the permittee is in the phase of developing a LTCP, there
will usually be a schedule that provides 2 years or less for the development and
submission of the plan, either in the permit or other appropriate enforceable
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Chapter Twelve Combined Sewer Overflows
mechanism. Where the permittee has completed a LTCP, there will be narrative
requirements pertaining to the implementation, operation, and maintenance of the
selected CSO controls described in the LTCP. There will also be a schedule for
implementation of the CSO controls either in the permit or in an appropriate
enforceable mechanism.
• Water quality-based effluent limits for CSOs. Numeric limits may not be found in the
initial permits when the permittee is developing or implementing its LTCP. Instead,
there will be a requirement to immediately comply with applicable WQSs expressed in
the form of a narrative limitation. Permittees that have completed and are
implementing their LTCPs may have one of the following permit conditions for CSOs:
- A maximum number of overflow events per year for specified design conditions
- Minimum percentage capture of combined sewage by volume for treatment under
specified design conditions
- Minimum percentage reduction of the mass of pollutants discharged for specified
design conditions
- Other performance-based standards and requirements.
• Requirements to implement a post-construction compliance monitoring program. This
will be required for permittees that have completed and are implementing their LTCPs.
• Requirement to re-assess overflows to sensitive areas. This will only be imposed in
those cases where elimination or relocation of CSOs from sensitive areas were proven
not to be physically possible or economically achievable.
• Conditions establishing requirements for maximizing the treatment of wet weather flows
at the treatment plant.
Other documents that the inspector should review are any CSO reports submitted by the
permittee. The permittee may have submitted information in response to EPA 308 information
requests on CSOs. The permittee may have submitted CSO monitoring plans or a report
characterizing its CSOs, a report documenting implementation of the nine minimum CSO
controls, or a Long-Term CSO Control Plan. Reviewing these permittee reports will help the
inspector become knowledgeable about the permittee's specific CSO problems and existing
CSO controls.
12-6
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Chapter Twelve Combined Sewer Overflows
Onsite Records Review
The types of CSO records that the inspector should find at the facility would be the following:
• Log books, reports, or internal memos describing maintenance and operation activities
concerning the sewer system and CSO outfalls
• CSO outfall flow records
• Monitoring data on CSOs, collection system, or receiving stream
• Records pertaining to installation of CSO controls.
The specific records that a facility would maintain will depend on the specific CSO controls the
facility has selected and is implementing. If the permittee has submitted a report documenting
implementation of the CSO controls, the inspector should review appropriate records kept at
the facility to verify the information in this report. Examples of possible records that might be
kept to document the implementation of the nine minimum CSO controls are listed in Table
12-3. These examples are provided as illustrations and not requirements. The inspector
should use the facility's permit or other enforceable document as a guide in determining what
specific records the facility is required to keep and maintain. The facility's CSO Operations
and Maintenance manual and CSO control plan can provide the inspector with insight into the
specific types of records the facility would have.
Interviews
As with all of the NPDES compliance inspections, interviews with appropriate personnel with
firsthand knowledge of CSO activities can be useful in obtaining factual information. The
inspector should interview the person in the highest position of authority responsible for the
day-to-day development or implementation of the LTCP. Other personnel, such as the
collection crew or others involved in inspecting, operating, and maintaining CSOs or CSO
controls should also be interviewed. It is particularly important that the inspector obtain written
statements (see Chapter Two) where personnel are providing information that is not or cannot
be substantiated by the facility's records or the inspector's own observations.
If the facility is developing or implementing a LTCP, the inspector may want to interview those
personnel responsible for that plan. Generally, the facility will be under a schedule with
distinct activities and milestones established. This schedule may be in the permit, but will
more likely be in an enforcement order. Any schedules submitted by the permittee in a report
or in its LTCP should not be referred to, as these are not enforceable schedules. The
inspector should focus on verifying those LTCP development or implementation activities that
(1) the permittee has reported have been developed/implemented and (2) the permittee was
required to have developed/implemented according to a schedule in the permit or enforcement
order.
12-7
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Chapter Twelve Combined Sewer Overflows
Facility Site Inspection
An inspection of the CSO outfalls is not normally part of an NPDES compliance inspection of
the wastewater treatment plant. However, if the inspection's focus or one of its objectives is
the investigation of compliance with CSO requirements, then the inspector may decide that an
inspection of CSO structures, CSO treatment systems, or key areas of the collection system is
necessary. If the intent of the inspection is to observe CSO treatment, it may be necessary to
schedule this inspection during or immediately after a wet weather event. These outfalls
would be located throughout the collection system and, therefore, may be several miles from
the facility.
It is not necessary to inspect all of the CSO outfalls. The inspector can select a few either
randomly or on the basis of location (closest to the plant) or other selection criteria. For
example, the inspector may want to inspect those outfalls that have some type of treatment of
solids and floatables to evaluate the operation and maintenance of the controls. The
inspector might also select the largest (in discharge volume) outfalls, those that most
frequently discharge (during wet weather), or those that are known to have an impact on water
quality. Conversely, the inspector may want to select those outfalls that are subject to few
inspections by the permittee.
If the inspector observes any dry weather CSO discharges, a photographic record should be
made (see Chapter Two), and indepth interviews should be held and statements obtained
from facility personnel.
12-8
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Chapter Twelve
Combined Sewer Overflows
Table 12-3.
CSO Records
Nine Minimum CSO Controls
Examples of Records/Documentation
Proper operations and regular
maintenance program
Log of sewer system cleaning, flushing, or debris
removal
Log of repair or maintenance of regulators
Log of lift station malfunctions and repairs made
Log of preventative maintenance of interceptor lift
stations and pumps
Log of inspections of lift stations, sewer lines, and
regulators
Maximum use of collection system for
storage
Hydraulic study of system and evaluation of
alternatives to maximize wet weather flow storage
capacity
Records of installation of in-line devices such as
dams, regulators, and gates to retard flow
Installation of separate sanitary and storm water
lines
Replacement of undersized pipes
Adjustment of regulator settings or
upgrading/adjusting pumping rates at lift stations
Off-line temporary storage
Review and modification of the
pretreatment program
Inventory of nondomestic discharges
Assessment of significance of nondomestic
discharges on CSO and receiving waters
Pretreatment controls to reduce/eliminate industrial
contaminants during wet weather
Maximization of flows to the POTW for
treatment
Summary of analyses conducted
Maximum wet weather flow Wastewater Treatment
Plant (WWTP) can receive without pass-through or
interference
Description of modifications to be implemented
12-9
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Chapter Twelve
Combined Sewer Overflows
Table 12-3.
CSO Records (Continued)
Nine Minimum CSO Controls
Examples of Records/Documentation
Prohibition of dry weather overflows
(DWOs)
Log of inspections of CSOs during dry weather and
observations made during these inspections
Log of Dry Weather Overflow (DWO) reports
submitted
Control of solids and floatable materials •
in CSOs
Installation of screens or booms
Source control activities such as regular street
cleaning, highly visible anti-litter programs
Pollution prevention
Street sweeping, anti-litter campaigns
Public notification
Date and proof of public notice, procedure (by
newspaper, radio), public notice information
Monitoring of CSOs
Identification of outfall locations
Number and location of overflow events including
duration, volume, and pollutant loadings
Receiving stream data and impact (e.g., beach
closings, fish kills)
Monitoring plan
12-10
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12. COMBINED SEWER OVERFLOWS
C. References and Checklist
References
Federal Register. April 19, 1994. Combined Sewer Overflow Control Policy; Notice. Volume
59, No. 75.
U.S. Environmental Protection Agency. April 1994. "Draft Combined Sewer Overflows
Guidance for Long-Term Control Plan." EPA 832-R-94-001.
U.S. Environmental Protection Agency. April 1994. "Draft Combined Sewer Overflows
Guidance for Nine Minimum Control Measures." EPA 832-R-94-002.
U.S. Environmental Protection Agency. April 1994. "Draft Combined Sewer Overflows
Guidance for Permit Writers."
12-11
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Chapter Twelve Combined Sewer Overflows
NOTES ***
12-12
-------
Chapter Twelve
Combined Sewer Overflows
CSO EVALUATION CHECKLIST
Yes No N/A
Yes . No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Yes
Yes
Yes
Yes
No
No
No
No
N/A
N/A
N/A
N/A
Yes
Yes
Yes
Yes
No
No
No
No
N/A
N/A
N/A
N/A
A. IDENTIFICATION OF CSOs
1. Are all CSO points identified?
2. Does facility have maps/schematics of Combined Sewer System (CSS)
depicting location of all CSO discharge points?
3. Is each CSO discharge point located by longitude, latitude, and street
address on appropriate maps?
B. DRY WEATHER OVERFLOWS
1.
2.
3.
4.
Are the locations of all dry weather CSOs known by permittee?
Does permittee have records of quantitative loads and flows on all dry
weather CSO events?
Has notification been given to EPA/State of all
discharges?
Are there any unreported dry weather CSOs?
dry weather CSO
C. RECORDS
Are the following records kept for CSO events?
• Location
• Frequency of discharge
• Flow magnitude
• Discharge pattern
• Total volume of discharge
• Pollutant characterization
• Correlation with rainfall records
• Specific causes of overflows
• Flow collected/flow diverted?
Are records of CSO flows maintained?
Are records accurate?
D. OPERATION AND MAINTENANCE
1.
2.
3.
4.
Is there a CSS O&M manual and does it address O&M of CSO structures?
Does the facility conduct inspections of the CSS and CSO structures?
Are these inspections documented? Does documentation include results of
various types of inspections, dates and times, corrective action taken if
problems were found?
Is a log book of maintenance and repair on the CSS and CSO structures
maintained? Does this note the type of problem (or indicate routine
maintenance), repair made, or maintenance activity conducted, date?
G. COMPLIANCE SCHEDULES
Is permittee meeting CSO compliance schedule for:
• Implementing nine minimum CSO controls?
• Developing LTCP?
• Implementing LTCP?
2. Has permittee requested an extension of time?
12-13
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Chapter Twelve Combined Sewer Overflows
*** NOTES ***
12-14
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13. POLLUTION PREVENTION
Contents Page
A. Overview of Pollution Prevention
Pollution Prevention Goals 13-1
Waste Management Hierarchy 13-1
Pollution Prevention Benefits 13-4
B. Pollution Prevention Opportunity Assessment Procedures For Industrial Facilities
Preparation 13-8
Interview 13-9
Facility Site Visit 13-10
C. Pollution Prevention Opportunity Assessment Procedures For Municipal Wastewater
Treatment Plants
D. References
List of Tables
13-1 Useful Facility Information to Conduct a Pollution Prevention Opportunity
Assessment 13-13
List of Figures
13-1 Waste Management Hierarchy 13-5
13-2 Benefits of Pollution Prevention -. . 13-6
13-3 Pollution Prevention Opportunity Assessment 13-12
Associated Appendices
R Pollution Prevention Checklist
13-i
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Chapter Thirteen Contents
NOTES
13-ii
-------
13. POLLUTION PREVENTION
A. Overview of Pollution Prevention
Pollution prevention is a proactive environmental management approach for minimizing
material and resource losses during production. Pollution prevention addresses all aspects of
production processes from raw material usage and inventory procedures to waste
management and utilities conservation. Management techniques that incorporate pollution
prevention reduce or eliminate the generation of pollutants, wastes, and adverse ecological
impacts through new approaches, material substitutions, and optimizing processes and
operating procedures.
Pollution Prevention Goals
The goal of pollution prevention is to achieve the reduction of pollution by the elimination or
reduction of waste. Pollution prevention is a multi-media approach that minimizes or
eliminates pollutants released to land, air, and/or water without shifting pollutants from one
medium to another. The Pollution Prevention Act of 1990 defines pollution prevention as:
...any practice which reduces the amount of a hazardous substance, pollutant, or
contaminant entering any waste stream or otherwise released into the environment
(including fugitive emissions) prior to recycling, treatment, or disposal; and any
practice which reduces the hazards to public health and the environment associated
with the release of such substances, pollutants, or contaminants.
Pollution prevention, therefore, represents a fundamental shift in approach away from the
conventional reliance on waste treatment/disposal or "end-of-pipe" treatment to the active
investigation of prevention techniques. Facilities can implement pollution prevention through:
• Equipment or technology modifications
• Process or procedure modifications
• Substitution of raw materials
• Improvements in housekeeping, maintenance, training, and/or inventory control.
Waste Management Hierarchy
The goal of a facility's pollution prevention program is to eliminate or reduce the generation of
pollutants and wastes at the source through careful consideration of materials usage,
production processes, and waste management practices. The facility's pollution prevention
program should identify opportunities for reducing the use of hazardous materials and the
generation of wastes or releases, as well as opportunities for protecting natural resources
through conservation and more efficient use of energy and water.
13-1
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Chapter Thirteen Pollution Prevention
The Pollution Prevention Act of 1990 includes a Waste Management Hierarchy that
schematically depicts a comprehensive waste management program. The hierarchy assigns
the highest priority to source reduction and places a decreasing level of preference on
recycling, treatment, and disposal. To be most effective, a facility's pollution prevention
program should focus on implementing source reduction. Where source reduction cannot be
achieved, reuse and recycling projects should be implemented. If there is no feasible pollution
prevention alternative, treatment and disposal should be used as a last resort. Figure 13-1 is
a graphic representation of the waste management hierarchy. Each level of the hierarchy is
described below.
Source Reduction
Source reduction refers to the use of materials, processes, or practices that reduce or
eliminate the quantity and toxicity of wastes at the point of generation. Preventing wastes
from being generated will decrease the need for costly treatment and disposal. Source
reduction opportunities include raw material substitutions, improved operating practices, and
process and equipment changes.
• Raw material substitution: Replacing hazardous materials with less hazardous (or
less toxic) alternatives reduces releases to the environment of hazardous materials
and wastes resulting from routine production processes and accidental spills.
Examples of source reduction include (1) the substitution of soy-based or water-based
ink to replace solvent-based ink for printing, (2) the use of recycled paper instead of
virgin stock, (3) the replacement of styrofoam packing materials with re-usable hard-
pack plastic materials for shipping products, (4) the elimination of trichloroethylene as a
cleaning agent through replacement with a caustic cleaner such as potassium
hydroxide or sodium hydroxide, and (5) the elimination of the use of freon.
• Improved operating practices: Improved operating practices can reduce waste
generated as a result of poorly developed standard operating procedures, inadequate
training, and inefficient production scheduling. In the past, facilities developed
operating practices that maximized production without taking into account factors such
as raw material usage, waste disposal costs, and environmental impacts. Examples of
improved operating practices include, but are not limited to, waste segregation, better
housekeeping, and establishment of preventive maintenance, training, and outreach
programs.
• Process and equipment modifications: In the long run, one of the most effective
source reduction techniques may involve process and equipment modifications.
Changes to processes and equipment present significant opportunities for source
reduction and pollution prevention. Such modifications include using newer or more
efficient equipment or redesigning a process so that less raw material is required, yet
product quality is maintained.
13-2
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Chapter Thirteen Pollution Prevention
Recycling
While source reduction prevents wastes from being generated, recycling turns by-products
and wastes into reusable products. Recycling includes such practices as onsite or offsite
recycling, materials exchange or reuse, and raw materials recovery.
• Onsite/offsite recycling: Both onsite and offsite recycling can help reduce
dependence on expensive virgin materials by reusing spent materials.
• Materials exchange or reuse: A materials exchange system maximizes the use of a
facility's excess raw materials and equipment. A system generally consists of a
database for tracking the availability of excess materials by department (or whatever
organizational unit is appropriate). In addition, a materials exchange system may
include a communication link with the facility's supply system to alert stock clerks that
excess items are on hand and should be used prior to purchasing new stock.
• Materials recovery: Some of the by-products and wastes generated during production
can be recovered and sold as commodities. One example of materials recovery is the
use of waste acids that no longer meet the requirements of a final, critical cleaning
process in a secondary process that does not require the same level of cleanliness.
Other examples of materials recovery as part of waste treatment are discussed below.
Waste Treatment
Unlike source reduction, waste treatment applies to wastes after generation. The goals of
waste treatment technologies are to neutralize the waste, to recover energy or material
resources, to render the waste nonhazardous, or to reduce the volume. Treatment
technologies that enable material to be recovered include ion exchange, reverse osmosis,
electrolytic metal recovery, and electrodialysis. Volume reduction through evaporation is an
example of treatment. Although volume reduction decreases the amount of wastewater, the
absolute quantity of hazardous or toxic waste released to the environment is not reduced. In
addition, equipment for volume reduction requires a capital cost and energy costs.
Waste Disposal
Disposal should be considered only when all other options are exhausted. Disposal is
considered the least favored waste management method because of the associated costs,
liability, and environmental impacts. In addition, a limited number of permitted waste sites are
available for disposing of hazardous material, and many of these sites are approaching
capacity. Also, the transportation of wastes may pose hazards. Finally, the recordkeeping
and reporting requirements associated with the disposal of hazardous wastes are an
additional burden that can be avoided through preventive measures, such as source
reduction.
13-3
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Chapter Thirteen Pollution Prevention
Pollution Prevention Benefits
Figure 13-2 summarizes the direct benefits to facilities through pollution prevention practices.
A key benefit of source reduction is the improved potential for environmental compliance. In a
time of increasingly stiff penalties for environmental violations, remaining in compliance is a
top priority.
The implementation of source reduction measures can also reduce costs associated with
waste management. The costs that may be reduced include expenditures for raw materials,
waste disposal, transportation, handling and storage, training, management overhead, and
emergency response. By decreasing the amount of hazardous waste shipped offsite for
disposal, the facility may also reduce the costs associated with tracking and filing paper work
required for hazardous waste manifests. Future costs, such as remediation activities, can also
be avoided with source reduction activities.
In addition, source reduction will produce positive health and environmental benefits. Having
less hazardous or toxic materials onsite will mean reduced occupational hazards, and,
therefore, improved worker health and safety. Creating a safer workplace may reduce the
need for expensive health and safety protection devices. Also, insurance cost may be
lowered. A safer workplace will also improve employee job satisfaction. Another benefit is
that reductions in the use of hazardous materials decrease the volume of toxic substances
released to the environment from spills, leaks, and air emissions.
The indirect benefits of pollution prevention may be equally significant. One indirect benefit is
reduced liability. The Resource Conservation and Recovery Act (RCRA) and Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) "cradle to grave"
provisions stipulate that a generator remains responsible for all environmental damage
resulting from its waste including damage that occurs after disposal. A pollution prevention
program can generate goodwill in the community and workplace, enhance the facility's public
image, and foster environmental awareness among employees.
13-4
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Chapter Thirteen
Pollution Prevention
Figure 13-1
Waste Management Hierarchy
Method
Source Reduction
Example Activities
• Environmentally
Friendly Design of
New Products
• Product Changes
• Source Elimination
Example Applications
• Modify Product to
Avoid Solvent Use
• Modify Product to
Extend Coating Life
Recycling
• Reuse
• Reclamation
• Solvent Recycling
• Metal Recovery
from a Spent Plating
Bath
• Volatile Organic
Treatment
^-
w
Stabilization
Neutralization
Precipitation
Evaporation
Incineration
Scrubbing
^-
. ^
• Thermal 1
. Destruction of 1
Ornanir ftolx/pnt 1
• Precipitation of 1
Heavy Metal from a 1
Disposal
^
w
• Disposal at a I
1 clllllllcU 1 uOIIILy • ^
Land Disposal
461B-04
13-5
-------
Chapter Thirteen Pollution Prevention
Figure 13-2
Benefits of Pollution Prevention
Significantly reduces the amount of pollution released to the environment.
Improves environmental and safety compliance.
Improves worker health and safety.
Provides the flexibility to choose cost-effective'and environmentally sound solutions that
will also result in improved efficiency and increased profit margins.
Provides public recognition of a facility's efforts.
Saves capital because of reductions in waste sent for costly treatment and disposal and
because of decreased raw materials and energy usage.
13-6
-------
13. POLLUTION PREVENTION
B. Pollution Prevention Opportunity
Assessment Procedures For
Industrial Facilities
Because the primary objective of a routine National Pollutant Discharge Elimination System
(NPDES) compliance inspection is an evaluation of the facility's compliance with its NPDES
permit requirements, a pollution prevention assessment incorporated into a compliance
assessment may, by necessity, be limited. Nevertheless, the inspector can use these routine
NPDES compliance inspections to identify pollution prevention options, particularly those
options that would improve compliance. Alternatively, a more comprehensive pollution
prevention assessment can be conducted if the facility visit is being conducted for this
purpose only. In this instance, the general procedure for a facility visit is the same as that for
any inspection (e.g., preparation, entry, opening conference, facility tour), but the specific
focus is on identifying pollution prevention opportunities for the facility to investigate. Two
reference documents the inspector may find useful are the Waste Minimization Opportunity
Assessment Manual (EPA/625/7-88/003) and the Facility Pollution Prevention Guide
(EPA/600/R-92/088). These documents contain procedures for conducting a pollution
prevention opportunity assessment. Pollution prevention opportunity assessments have four
phases: (1) planning and organization, (2) assessment, (3) feasibility analysis, and
(4) implementation. The four phases are summarized in Figure 13-3.
The inspector cannot perform all the steps in the type of pollution prevention assessment
described in the Waste Minimization Opportunity Assessment Manual (EPA/625/7-88/003) and
in the Facility Pollution Prevention Guide (EPA/600/R-92/088). These documents were
developed as guides for waste generators who want to implement a pollution prevention
program. The feasibility analysis and implementation phases require development of criteria
to screen and rank the options, an indepth technical assessment on whether the options can
be successfully applied at that facility, an economic evaluation, and the development of an
implementation plan and schedule, which only the facility can determine. However, the
inspector can evaluate whether the facility has conducted such an assessment and whether
there are obvious pollution prevention opportunities.
It will be impossible, and unnecessary, for the inspector to have indepth knowledge and
understanding of all production processes and facility activities. However, as part of the entire
pollution prevention assessment, whether during the preparation, interview, or facility site visit,
the inspector should strive to become familiar with the facility layout, equipment and
processes, points of potential waste generation, types of waste generated, and how waste is
handled and disposed of. If possible, the inspector should collect sufficient detailed
information to develop a general flow diagram or material balance for each process step. The
inspector should know the source, type, quantity, and concentration of each identified
wastestream in order to identify data gaps, problem areas, and data conflicts.
13-7
-------
As the assessment is conducted, the inspector should keep the pollution prevention principles
in mind:
• Multi-media focus looking at all environmental media as a unified whole to avoid
transfers from one medium to another
• Comprehensive evaluation of the total environmental impacts over the lifecycle of the
produce, from raw materials through manufacturing (including energy use) to use and
ultimate disposal.
Preparation
The inspector should prepare for the assessment by examining information about the
processes, operations, and waste management practices at the facility. Any background
material should be reviewed in the facility's file. If the inspection is planned to focus on
pollution prevention assessment, the inspector should contact the facility to inform plant
officials of this objective. During this initial contact, the inspector should ask for information
that will help identify potential pollution prevention options. Table 13-1 provides a list of useful
information for this assessment.
As the inspector reviews facility information, he or she should develop a list of questions
specific to the facility. The inspector should be seeking, through the facility-specific questions,
information to answer the following general questions:
• What significant wastestreams are generated by the plant? How much waste is
generated?
• Why are these considered "waste"?
• From which processes or operations do these waste streams originate?
• What is the production rate of each wastestream?
• Which wastes are hazardous and which are not? What makes them hazardous?
• How are the wastes managed at present?
• What are the input materials used that generate the wastestreams of a particular'
process or plant area?
• How efficient is the process? How much input material is:
- Used in a process?
- Released to water or air, or disposed of on land?
- Destroyed or unaccounted for?
• What types of process controls are used to improve process efficiency?
• Are unnecessary wastes generated by mixing otherwise recyclable or recoverable
hazardous wastes with other process wastes?
13-8
-------
• What types of housekeeping practices are used to limit the quantity of wastes
generated?
• Has the plant developed a Pollution Prevention Plan or strategy?
There are numerous documents that identify pollution prevention techniques for specific types
of industries, such as the metal finishing industry, the fabricated metal products industry, and
the pharmaceutical industry. These documents and other pollution prevention information can
be obtained from:
• Pollution Prevention Information Clearinghouse (PPIC)
- Guidance and information on Pollution Prevention Opportunities, (202) 260-1023
• Pollution Information Exchange System (PIES)
- Electronic Bulletin Board on Pollution Prevention Information, (703) 506-1025
• Center for Environmental Research Information (CERI)
- Guidance and Information on Environmental Protection Programs, Publications Unit,
U.S. EPA, 26 West Martin Luther King Drive, Cincinnati, OH 45268, (513) 569-
7562, (513) 569-7566 (fax)
Interview
Just as with a routine NPDES compliance inspection, plant personnel should be interviewed
when the inspector first arrives at the facility. The inspector should target personnel from the
following areas:
• Management
• Environmental waste management
• Process engineering
• Facility maintenance
• Operation and production
• Safety and health
• Research and development
• Quality control
• Purchasing/inventory
• Shipping/receiving
• Storage.
From the interviews, the inspector should develop (or verify) a list of all waste minimization
practices already in place. The inspector should also ask plant personnel for the plant's
Pollution Prevention Plan or strategy and any suggested pollution prevention opportunities in
the operations and processes and discuss with the plant personnel any pollution prevention
opportunities that were identified during preparations for the site visit or during the onsite
interviews.
13-9
-------
Facility Site Visit
Again, as with a routine compliance inspection, the inspector should conduct a tour of the
facility with plant personnel after the interview. The same areas of the manufacturing facility,
materials and waste storage, loading and unloading, and treatment system should be
reviewed. At each process area, the plant personnel most knowledgeable about the activity
should describe the process or should answer any questions the inspector may have.
The inspector should make personal observations, seek confirmation of the interpretation of
an activity that is occurring, and investigate any information plant personnel provide that
appears to contradict what is being observed. The inspector should focus on:
• Loading and unloading operations
• In-plant transfers (raw materials handling)
• Process operations
• Housekeeping practices
• Maintenance activities
• Waste management operations.
The inspector should also check for signs of spills or leaks and assess overall cleanliness of
the site. Throughout all the areas visited, the following wastestreams should be evaluated:
• Wastewater
• Air emissions, including stack and fugitive emissions (e.g., detectable odors and fumes)
• Hazardous wastes
• Nonhazardous solid wastes.
Each wastestream should be reviewed to:
• Determine whether the wastes are hazardous or nonhazardous
• Determine other physical and chemical characteristics of wastes and emissions
• Determine actual points of generation
• Determine quantities including variations
• Identify all handling, treatment, and storage procedures onsite.
By using the activities described above during a facility tour, the inspector should look for
pollution prevention opportunities in the following general areas:
• Substituting less hazardous materials such as:
- Using latex or water-based paints, rather than oil-based
- Eliminating organic solvent cleaners and replacing with aqueous cleaners
• Limiting the amount of hazardous materials disposed of by:
- Buying only the amount of material the facility needs
- Using all materials before their expiration date
- Using only the amount of material needed
- Sharing materials or donating extra materials to community organizations.
13-10
-------
• Using and storing products carefully to prevent:
- Accidents and spills
- Mixtures of incompatible materials that can react, ignite, or explode.
• Recycling wastes, such as:
- Used oil
- Plastics, glass, paper, and metals
- Spent solvents.
• Generating less pollution by:
- Automating and improving process controls to optimize production operations
- Allowing products to fully drain process chemicals before rinsing
- Using less toxic materials (e.g., printing inks, dyes)
- Adjusting production schedules to minimize cleanup operations
- Sealing floor drains (permanently or temporarily) to prevent spills
- Segregating wastes to support recycling (e.g., scrap metals, solvents).
• Turning waste products into new materials by:
- Treating and recycling rinse waters
- Recovering metals such as silver from waste materials
- Recycling waste lubricants and coolants.
• Using fewer resources by:
- Installing flow restrictors on rinse waters
- Installing high efficiency boilers and furnaces
- Using heat exchangers to heat process water supplies.
• Educating employees on the:
- Goals of pollution prevention and waste management
- Procedures to follow for waste disposal and pollution prevention
- Accomplishments for the pollution prevention program being implemented.
Before leaving the facility, the inspector should meet with plant personnel. A list of pollution
prevention options identified during the site visit should be prepared and discussed with plant
personnel. Inspectors can discuss a pollution prevention technology or refer the facility
representatives to EPA or State pollution prevention technical assistance offices. However,
the inspector should not recommend specific measures to implement. Nor should the
inspector suggest particular products or imply that a certain pollution prevention measure will
enable the facility to achieve compliance.
13-11
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Figure 13-3
Pollution Prevention Opportunity Assessment
The recognized need to minimize waste
Planning and Organization
• Get management commitment
• Set overall assessment program goals
• Organize assessment program task force
Assessment organization and
commitment to proceed
Assessment Phase
Collect process and facility data
Prioritize and select assessment targets
Select people for assessment teams
Review data and inspect site
Generate options
Screen and select options for further study
Assessment report
of selected options
T
Feasibility Analysis Phase
Technical evaluation
Economic evaluation
Select options for implementation
Final report, including
recommended options
T
Implementation
Justify projects and obtain funding
Installation (equipment)
Implementation (procedure)
Evaluate performance
T
Select new
assessment
targets and
reevaluate
previous
options
Successfully implemented
waste minimization projects
461b-03
13-12
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Table 13-1
Useful Facility Information to Conduct a Pollution Prevention Opportunity Assessment
Raw Materials Information
Product composition
Material Safety Data Sheets
Product and raw material inventory and purchasing records
Operator data logs
Production schedules and records
Manufacturing Process Information
Process flow diagrams
Material and heat balances for production
Manufacturing and pollution control processes
Operating manuals and process descriptions
Water usage rates
Equipment and equipment specifications
Piping and instrument diagrams
Sewer layout diagrams
Facility layout and elevation plans
Equipment layouts and work flow diagrams
Waste Generation and Disposal Information
Environmental permits—air emissions, solid waste, hazardous waste, NPDES,
pretreatment
RCRA information—manifests, annual reports
Location of all wastewater, solid and hazardous waste collection, treatment, and
storage points
Diagram of air, wastewater, and/or hazardous waste treatment units
Operating manuals for treatment units
Emissions inventories [air, NPDES Discharge Monitoring Reports (DMRs), etc.]
SARA Title III—Section 313 release reports
Previous regulatory violations
13-13
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*** NOTES ***
13-14
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13. POLLUTION PREVENTION
C. Pollution Prevention Opportunity
Assessment Procedures For
Municipal Wastewater Treatment
Plants
The Municipal Water Pollution Prevention (MWPP) program promotes the application of
pollution prevention concepts of the Pollution Prevention Act to publicly owned treatment
works. Pollution prevention can reduce the need for substantial capital investment in new
infrastructure, enhance worker safety, improve the usability of sludge, and reduce operation
and maintenance costs. Practices that stress a preventive approach to water pollution
abatement include the following:
• A mechanism for routine assessments of the compliance status of Publicly Owned
Treatment Works (POTWs). This mechanism should include an early warning system
based on periodic self-audits and quantitative techniques for assessing the condition of
municipal wastewater treatment systems.
• A reporting process on the capability of POTWs to sustain compliance.
• A process for identifying, implementing, and tracking corrective actions to prevent
pollution and maintain compliance.
• A program that will encourage POTWs to develop pollution prevention projects.
Pollution prevention practices POTWs can adopt could focus in the areas of:
• Improved operation and maintenance
• Projects that reduce wastewater flows and pollutant loadings
• Energy and water conservation
• Timely planning and financing for future needs and economic growth prior to
occurrence of wastewater permit violations
• Toxicity reductions at the source (industrial pretreatment, commercial and residential
source reduction programs)
• Recycling
• Proper treatment of wastes
• Beneficial uses of sludge.
13-15
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Specific opportunities for optimizing each unit operation to maximize removal efficiency may
include unit modifications to improve performance. For example:
• Clarifiers — Baffle installations and weir modifications to improve hydraulics and limit
short circuiting
• Aeration basins — Baffles to limit short circuiting. Fine bubble diffusers to improve
aeration. Use of automatic controls to optimize aeration and limit over-aeration.
• Aerobic digester — Recover energy from gas. Insulate digester.
At any time, but especially during upgrading and expansion, the following pollution prevention
projects could be considered:
• Install high efficiency pumps, motors and drives.
• Use biological- rather than chemical-based treatment.
• Install equalization basins to improve efficient operation of downstream units and
minimize the need for oversize units.
• Design plant layout to minimize the need for intermediate pumping.
• Consider ultraviolet or ozone disinfection instead of chlorine.
• Digest residuals rather than heat or chemical treat.
• Select dewatering equipment not only to maximize solids but to minimize the need for
chemical feeds that increase the volume of residuals.
• Evaluate toxicity of all lubes, solvents, or cleaners, and replace them with less toxic
alternatives such as citrus-based cleaners wherever possible.
• Reduce infiltration/inflow, which will result in several benefits:
— Reduces plant expansion needs
— Improves performance efficiency
— Reduces grit (which increases equipment wear and breakage and is a disposal
problem).
The Industrial Pretreatment Program is one of the best opportunities to achieve pollution
prevention. It represents source control. Pollution prevention programs or projects aimed at
residential and commercial users can also reduce loadings. Such pollution prevention
programs could:
• Encourage water conservation.
• Provide information on compatible or biodegradable cleaners to replace more toxic
cleaners (for example, identify an alternative to chlorine-based "hang-in" type toilet
bowl cleaners).
13-16
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• Encourage composting instead of garbage grinders.
• Enforce a commercial oil and grease ordinance requiring installation, operation, and
maintenance of grease traps and recovery and recycle of oil and grease.
• Discourage oil and grease dumping.
• Prohibit disposable diaper flushing.
The POTW could also work with water utilities or agencies involved in establishing plumbing
codes to reduce the metals (zinc, copper, and lead) found in drinking water supplies. These
metals may be present because the water is corrosive to the pipes and leaches the metals
from copper tubing, zinc-coated iron and steel pipes, and lead solder. The water utility may
also be using water conditioning chemicals that contain metal salts.
The protocols for conducting a pollution prevention assessment at municipal wastewater
treatment plants are similar to those for an industrial facility. The protocols of a Compliance
Evaluation Inspection (CEI) are also appropriate, except that the focus during the interview,
file review, and site visit is on identifying pollution prevention opportunities.
13-17
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NOTES ***
13-18
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13. POLLUTION PREVENTION
D. References
U.S. Environmental Protection Agency. July 1988. Waste Minimization Opportunity
Assessment Manual. EPA/625/7-88/003.
U.S. Environmental Protection Agency. Facility Pollution Prevention Guide. EPA/600/R-
92/088.
University of Tennessee. Waste Reduction Assessment and Technology Transfer (WRATT)
Training Manual, 2nd Edition.
Municipal Water Pollution Prevention Program. March 1991. 21W-7002.
13-19
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NOTES
13-20
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14. MULTI-MEDIA CONCERNS
Contents Page
A. Introduction
B. Overview of the Multi-Media Approach to Inspections
C. Multi-Media Concerns at NPDES Facilities and the Multi-Media Screening Program
RCRA 14-5
RCRA/CERCLA 14-6
Nonhazardous Sludge 14-6
Air 14-6
Multi-Media Screening 14-7
D. NPDES Inspectors and Multi-Media Inspections
Description of a Multi-Media Inspection 14-9
The NPDES Inspector's Role in a Multi-Media Inspection 14-10
E. References
Associated Appendices
S Media-Specific Inspection Components
T National Multi-Media Screening Inspection Checklist
14-i
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Chapter Fourteen Contents
NOTES
14-ii
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14. MULTI-MEDIA CONCERNS
A. Introduction
This chapter is intended as a guide for National Pollutant Discharge Elimination System
(NPDES) inspectors who become involved in multi-media environmental compliance
inspections. Multi-media compliance investigations are intended to determine a facility's
status of compliance with applicable laws, regulations, and permits in more than one medium.
This chapter and the Media and Specific Inspection Components contained in Appendix S
include a significant amount of material drawn directly from the National Enforcement
Investigations Center's (NEIC's) "Multimedia Investigation Manual" revised March 1992.
NPDES inspectors participating in multi-media inspections are referred to that document for
further guidance.
14-1
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Chapter Fourteen Multi-Media Concerns
NOTES ***
14-2
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14. MULTI-MEDIA CONCERNS
B. Overview of the Multi-Media
Approach to Inspections
All inspections can be grouped into four categories of increasing complexity, moving from
Category A (program-specific compliance inspections) to Category D, (complex multi-media
investigations), depending upon the complexity of the facility and the objectives of the
investigation. The four categories of investigations are described below:
Category A: Program-specific compliance inspections (e.g., compliance with NPDES permit
requirements), conducted by one or more inspectors. The objective is to
determine facility compliance status for program-specific regulations.
Category B: Program-specific compliance inspections, which are conducted by one or more
inspectors. The inspector(s) screen for and report on obvious key indicators of
possible noncompliance in other environmental program areas.
Category C: Several concurrent and coordinated program-specific compliance investigations
conducted by a team of investigators representing two or more program offices.
The team, which is headed by team leader, conducts a detailed compliance
evaluation for each of the target programs. The objective is to determine
compliance for several targeted program-specific areas. Reports on obvious,
key indicators of possible noncompliance in other environmental program areas
are also made.
Category D: These comprehensive facility evaluations not only address compliance in
targeted program-specific regulations, but also try to identify environmental
problems that might otherwise be overlooked. The initial focus is normally on
facility processes to identify activities (e.g., new chemical manufacturing) and
by-products/wastestreams potentially subject to regulation. When regulated
activities or wastestreams are identified, a compliance evaluation is made with
respect to applicable requirements.
The investigation team, headed by a team leader, comprises staff thoroughly
trained in different program areas. The on-site investigation is conducted
during one or more site visits and involve intense concurrent program-specific
compliance evaluations, often by the same cross-trained personnel.
Category D multi-media investigations are thorough and, consequently,
resource intensive. They are appropriate for intermediate to large, complex
facilities that are subject to a variety of environmental laws. Compliance
determinations are made for several targeted program-specific areas, and
reports on possible non-compliance are prepared.
14-3
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Chapter Fourteen Multi-Media Concerns
'Generally, all investigations will use essentially the same protocols, including pre-inspection
planning, use of a project plan, sampling, inspection procedures, and a final report. The major
difference will be in the number of different regulations addressed during Categories C and D
investigations.
The multi-media approach to investigations has several advantages over program-specific
inspections, including:
• A more comprehensive and reliable assessment of a facility's compliance with fewer
missed violations.
• Improved enforcement support and better potential for enforcement.
• A higher probability to uncover/prevent problems before they occur or before they
manifest an environmental or public health risk.
• Ability to respond more effectively to non-program-specific complaints, issues, or needs
and to develop a better understanding of cross-media problems and issues, such as
waste minimization
• Less resource intensive.
The success of a multi-media investigation program is contingent upon a good managerial
system and the support of upper management. Since these investigations will often be
conducted at larger facilities, adequate resources (time and personnel) must be provided.
Good communications during the planning phase are essential to define the scope of the
inspection, as well as each team member's role. Communications could also include State
officials since State inspectors might also participate as team members. Because of the
extent of the State's knowledge of the facility and its problems, State involvement is often
critical to the success of the investigation. Similarly, coordination with other Federal or local
agencies needs to be addressed, as necessary.
14-4
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14, MULTI-MEDIA CONCERNS
C. Multi-Media Concerns at NPDES
Facilities and the Multi-Media
Screening Program
RCRA
Many NPDES-regulated facilities are also subject to requirements of the Resource
Conservation and Recovery Act (RCRA). RCRA regulates the generation, transportation,
treatment, storage, and disposal of hazardous wastes. However, RCRA defers the control of
hazardous wastes to the Clean Water Act (CWA) when those wastes are either directly
discharged to surface waters (the direct discharge exclusion) or indirectly discharged to a
wastewater treatment plant (the domestic sewage exclusion).
The costs of hazardous waste management using "traditional" storage, treatment, and
disposal methods are rising significantly as facilities comply with the 1984 RCRA
Amendments. Consequently, industrial facilities may use the two previously mentioned
exclusions as preferred disposal methods. Since many of the 126 priority pollutants listed in
the CWA would be considered hazardous waste constituents under RCRA, the discharge of
these pollutants should concern the inspectors and operators of wastewater treatment plants.
Hazardous wastes discharged to wastewater treatment plants pass through to surface waters
unless incidentally removed in sludge, degraded, or "lost" through volatilization or exfiltration
during the wastewater treatment process.
NPDES permit writers and inspectors may learn whether the facility conducts RCRA regulated
activities, and the nature of those activities, from State and/or Environmental Protection
Agency (EPA) RCRA authorities or databases such as Facility Index System (FINDS).
Industrial facilities can use and/or generate hazardous waste. The hazardous wastes may be
in the liquid, gas, or solid form. These wastes may be generated from raw materials, off-
specification products, or residuals or emissions from the process operations. In addition,
waste oils used by process equipment, solvents used in cleaning operations, or sludges from
treatment of process wastewaters can be hazardous wastes.
Publicly Owned Treatment Works (POTWs) receiving hazardous wastes by truck, rail, or
dedicated pipeline are subject to RCRA permit by rule requirements. Included among these
requirements is the provision that corrective action must be taken to remedy any
contamination that may have resulted from a release of hazardous waste or hazardous
constituents from solid waste management units, such as surface impoundments, to the
environment. For example, if a POTW that is subject to these RCRA requirements
contaminates ground water through leaching or exfiltration, the permittee might be required to
investigate the nature and extent of those releases and, where appropriate, implement
14-5
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Chapter Fourteen Multi-Media Concerns
corrective measures. Guidance on the nature of these requirements, and how they might
affect POTWs, is now being developed.
RCRA/CERCLA
Another source of contaminated wastewaters is hazardous waste cleanup actions. Under
RCRA and the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), EPA, States, and private parties are initiating cleanups of contaminated sites.
Much of the waste found at these sites is in liquid form, either as leachate or contaminated
ground water. The treatment, and consequent discharge, of contaminated wastewaters from
these sources is expected to increase in the future. These wastes will likely be complex
mixtures, requiring careful examination of their composition to determine appropriate treatment
techniques.
Nonhazardous Sludge
It has long been known that wastewater treatment results in the transfer of residuals from
wastewater effluents to sludges. Several statutes and regulations, including the CWA, are
charged with management of these nonhazardous sludges. Future NPDES permits will
include disposal limitations for municipal sewage sludge as specified in 40 CFR Part 503.
Many States already impose such requirements. NPDES inspectors will need to become
more familiar with the relationship between State sewage sludge requirements and Federal
sewage sludge management and disposal requirements under the CWA and those imposed
by other statutes and regulations, particularly RCRA and the Clean Air Act (CAA). Municipal
sewage sludge that is co-incinerated with other wastes is regulated by the CAA. Municipal
sewage sludge that is co-disposed with other waste in a municipal solid waste landfill is
regulated by 40 CFR Part 258. Industrial sludges are regulated by 40 CFR Part 257 if land
applied and by 40 CFR Part 258 if disposed of in a nonhazardous landfill.
Air
Air emissions from wastewater treatment units are under increasing scrutiny. For organic
chemical facilities, EPA is now considering developing wastewater treatment controls which
explicitly recognize that treatment processes, such as air stripping, result in the transfer of
volatile organics from wastewater effluents to the air. EPA is also considering air emissions
from domestic wastewater treatment plants from two perspectives: ambient air quality
concerns and a concern for worker health and safety. In another development, the 1984
RCRA amendments provide for the control of air emissions from authorized RCRA Treatment,
Storage, and Disposal Facilities (TSDFs). As a result, wastewater treatment facilities at RCRA
TSDFs are now being investigated by RCRA program personnel. Remedial actions may be
required at some of these facilities and the regulatory issue of emissions from wastewater
treatment facilities will be addressed.
14-6
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Chapter Fourteen Multi-Media Concerns
Multi-Media Screening
Regions and States are encouraged to incorporate multi-media screening into as many single
medium inspections as possible (i.e., conduct Category B inspections in lieu of Category A
inspections). Obtaining multi-media screening information earlier in the process will help
target inspection resources and ensure that all non-compliance issues are included in any
facility-specific enforcement strategy. The compliance inspector will use a multi-media
screening checklist as a guide for making and recording observations and pertinent
information.
The Environmental Services Division Field Branch Chiefs and NEIC have led the development
and implementation of EPA's multi-media inspection program, including screening inspections.
The National Multi-Media Screening Inspection Checklist, dated May 12, 1993, was developed
as a general guideline by a Regional work group led by Region 3. A copy of this checklist is
included in Appendix T.
14-7
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Chapter Fourteen Multi-Media Concerns
*** Mrvrpc ***
NOTES
14-8
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14. MULTI-MEDIA CONCERNS
D. NPDES Inspectors and Multi-Media
Inspections
Description of a Multi-Media Inspection
The strategy developed for multi-media inspections usually involves prioritizing the processes
and waste management activities, followed by systematically moving from the beginning to the
end of a process with emphasis on regulated waste stream generation and final disposition.
The strategy should be somewhat flexible so that "mid-course corrections" can be made.
The compliance evaluations also need to be "sequenced" to progress, generally, from the
most to least time consuming regulatory program. Personnel training and availability and
other logistical factors may result in a combining of compliance evaluations. RCRA is often
chosen as the initial focus because of the close relationship between process evaluations and
generator requirements. Thus, the inspection of hazardous waste storage areas and
Polychlorinated Biphenyl (PCB) transformers is often conducted early in the inspection,
followed by the rest of the RCRA inspection. Compliance with regulatory programs that
principally involve records reviews, such as TSCA, Emergency Planning and Community Right
to Know Act (EPCRA), and CAA, are usually scheduled later in the inspection, as time
permits.
The strategy for process and compliance evaluations should be developed by the inspection
team coordinator and discussed with inspection team members. This will serve as the basis
for explaining inspection activities and scheduling to the company during the opening
conference.
The strategy should include checklists that address potential process wastestreams to be
examined and media-specific compliance issues. Checklists can be a vital component of a
compliance investigation to help ensure that an investigator does not overlook anything
important. Checklists serve as a reminder of what needs to be asked or examined and to
help an inspector remember the basic regulatory requirements.
In larger facilities, multiple site visits coordinated by the team leader may be necessary and
desirable for completing the inspection. This approach can lead to a better inspection
because of the opportunity to review information obtained in the office, then refine the
inspection/strategy to "fill in the gaps" during a subsequent site visit.
14-9
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Chapter Fourteen Multi-Media Concerns
The NPDES Inspector's Role in a Multi-Media Inspection
Each multi-media investigation team member should bring special program expertise and
experience and must be well trained in most facets of conducting a field investigation,
including sampling. Most of the investigators on the team, including the team leader, should
be current field investigators who already possess most of the necessary skills and
qualifications. EPA Order 3500.1 sets forth specific training requirements for any EPA
investigator who is leading a single medium investigation. These training requirements
include both general inspection procedures and media-specific procedures. While an
individual leading a multi-media investigation may not have had the media-specific training for
each medium covered during that multi-media investigation, the team leader should have the
media-specific training for at least two of the media.
The team leader has overall responsibility for the successful completion of the multi-media
investigation. In addition, other investigators may be designated as leads for each of the
specific media/programs that will be addressed. These individuals may work alone or have
one or more inspectors/samplers as assistants, depending on workload and training
objectives. However, all investigation team members should report directly to, and be
accountable to, the team leader.
The following are some of the more important skills and qualifications that are necessary for
team members:
• Knowledge of the Agency's policies and procedures regarding inspection authority,
entry procedures/problems, enforcement actions, legal issues, and safety
• Thorough understanding of sampling equipment; quality assurance (QA) requirements
for sample collection, identification, and preservation; and chain-of-custody procedures
• Knowledge of manufacturing/waste producing processes, pollution control technology,
principles of waste management, flow measurement theory and procedures, and waste
monitoring techniques/equipment
• Investigatory skills including the ability to gather evidence through good interviewing
techniques and astute observations
• Ability to convey information gathered during the inspection into clear, understandable
investigation reports.
• Up-to-date experience in conducting compliance inspections
• Good communication skills
• Basic understanding of the procedures of obtaining administrative warrants, including
preparation of affidavits, technical content of the warrant application, and warrant and
procedures for serving a warrant
14-10
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Chapter Fourteen Multi-Media Concerns
• At least one team member should have considerable knowledge of laboratory
(analytical) methods and Quality Assurance (QA) requirements, if a laboratory
evaluation is to be conducted
• For each of the areas addressed in the multi-media investigation, at least one team
member should be trained.
Investigators should conduct themselves in a professional manner and maintain credibility. A
cooperative spirit should be cultivated with facility representatives, when possible. All
investigators should maintain a sensitivity to multi-media issues and implications and freely
discuss, with other members of the team, observations/findings relating to one or more
programs.
Investigators should restrict their onsite activities to the normal working hours of the facility, as
much as possible. Investigators will need to keep abreast of specific program regulations and
should also coordinate, as necessary, with other EPA and State inspectors and laboratory
staff (if samples will be collected). The investigation team should implement appropriate field
note taking methods and proper document control procedures, particularly when the company
asserts a "confidential" claim. Investigators must ensure that important documents (e.g.,
project plan, safety plan, and logbooks) are not left unattended at the facility. Sensitive
discussions do not take place in front of facility personnel or on company telephones.
14-11
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Chapter Fourteen Multi-Media Concerns
*** NOTES ***
14-12
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Chapter Fourteen Multi-Media Concerns
E. References
NEIC. March 1992. Multimedia Investigation Manual.
14-13
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Chapter Fourteen Multi-Media Concerns
*** NOTES ***
14-14
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APPENDIX A
EPA ORDER 1440.2 HEALTH AND SAFETY
REQUIREMENTS FOR EMPLOYEES ENGAGED
IN FIELD ACTIVITIES
-------
-------
Appendix A EPA Order 1440.2
ENVIRONMENTAL
PROTECTION ORDER
AGENCY
1440.2
July 12, 1981
PROTECTIVE SERVICES - SAFETY
HEALTH AND SAFETY REQUIREMENTS FOR EMPLOYEES ENGAGED
IN FIELD ACTIVITIES
1. PURPOSE. This Order establishes policy, responsibilities, and mandatory requirements
for occupational health and safety training and certification, and occupational medical
monitoring of Agency employees engaged in field activities.
2. DEFINITIONS.
a. The term "field activities" as used in this Order means EPA program activities that
are conducted by EPA employees outside of EPA administered facilities. These activities
include environmental and pesticides sampling, inspection of water and wastewater treatment
plants, and hazardous material spills and waste site investigations, inspections, and sampling.
b. The term "health and safety training" means scheduled, formal or informal training
courses, approved and sponsored by EPA and conducted by EPA or its contracted agents
which is designed to develop, improve and upgrade the health and safety knowledge of EPA
employees involved in field activities.
c. The term "occupational medical monitoring" means surveillance over the health status
of employees by means of periodic medical examinations or screening in accordance with the
Agency's Occupational Medical Monitoring guidelines.
d. The term "certification" as used in this Order means that the employee has
successfully completed the minimum classroom and field training requirements for the
specified level of training and the Agency has issued a certificate attesting that the employee
met these requirements.
3. REFERENCES.
a. 29 CFR 1910, Parts 16, 94, 96, 106, 109, 111, 134, 151, 1000, Occupational Health
and Safety Standards.
A-1
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Appendix A EPA Order 1440.2
1440.2
ORDER
July 12, 1981
b. Executive Order 12196, Section 1-201, Sec. (k), Occupational Health and Safety
Programs for Federal Employees.
c. 29 CFR 1960.59(a), Occupational Safety and Health for the Federal Employee.
d. EPA Occupational Health and Safety Manual, Chapter 7(1).
e. EPA Training and Development Manual, Chapter 3, Par 7(b).
f. Occupational Health and Safety Act of 1971, P.L. 91-596, Sec.6.
g. EPA Order on Respiratory Protection (Proposed).
h. 49 CFR, Parts 100-177, Transportation of Hazardous Materials.
i. EPA Order 1000.18, Transportation of Hazardous Materials.
j. EPA Order 3100.1, Change 1, Uniforms, Protective Clothing, and Protective
Equipment.
4. BACKGROUND. Field activities are a critical part of most EPA programs. These
activities range from routine environmental reconnaissance sampling, inspections, and
monitoring, to entering and working in environments with known and unknown hazards. Since
protection can not be engineered into the field working situation, the protection of personnel
engaged in field activities involves training employees in safe operational procedures and the
proper use of appropriate personal protective clothing and equipment.
5. APPLICABILITY. This Order applies to all EPA organizational units which have
employees engaged in field activities.
6. POLICY. It is the policy of the Environmental Protection Agency to carry out its field
activities in a manner that assures the protection of its employees.
7. RESPONSIBILITIES.
a. Assistant Administrators. Regional Administrators. Deputy Assistant Administrators,
Laboratory Directors, and Division Directors. These officials are responsible within their
jurisdictions for implementing the provisions of this Order and for budgeting the necessary
funds for employee training and certification, personal protective clothing and equipment, and
occupational medical monitoring programs.
A-2
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Appendix A EPA Order 1440.2
ORDER
1440.2
July 12, 1981
b. Supervisors. Supervisors are responsible for complying with the requirements of
this Order for employee training and certification, and occupational medical monitoring
programs. They will identify those employees who require training and certification, and
occupational medical monitoring, and assure they receive it to comply with the provisions of
this Order and will insure these requirements are properly contained in position descriptions
and job postings.
c. Employees. Employees are responsible for making known upon request from their
supervisors the extent of their individual occupational, health and safety training and the
history of their occupational medical monitoring participation. Employees should notify their
supervisor of any hazardous work situation and make suggestions for corrective measures.
Employees are responsible for applying the knowledge, skills, and techniques acquired
through training in a manner that will help assure their health and safety and that of fellow
workers.
d. Occupational Health and Safety Designees. The Occupational Health and Safety
Designees are responsible for identifying program areas that require training and certification,
and occupational medical monitoring; recommending or providing training and certification
resources to meet the requirements of this Order; and maintaining records of persons
receiving training and certification.
e. Office of Occupational Health and Safety. The Director, Office of Occupational
Health and Safety is responsible for establishing policy and requirements for adequate training
and certification programs for field activities, developing and maintaining an occupational
medical monitoring program, approving health and safety training and certification programs
for employees involved in field activities, and for evaluating the results of these training and
certification programs.
8. OBJECTIVES.
a. Training and Certification. The objective of the health and safety training and
certification programs for employees involved in field activities are:
(1) To assure that EPA employees are aware of the potential hazards they may
encounter during the performance of field activities;
(2) To provide the knowledge and skills necessary to perform the work with the
least possible risk to personal health and safety;
(3) To assure that Agency program goals are accomplished in as safe and
healthful manner as feasible; and
A-3
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Appendix A EPA Order 1440.2
ORDER
1440.2
July 12, 1981
(4) To assure that EPA employees can safely disengage themselves from an
actual hazardous situation which may occur during a field activity.
b. Occupational Medical Monitoring. The objectives of the occupational Medical
Monitoring program are:
(1) To detect any adverse effects of occupational exposure on the employees
health and to initiate prompt corrective actions when indicated; and
(2) To assure that employees assigned arduous or physically taxing jobs or jobs
requiring unique skills are able to perform those jobs without impairing their health and safety
or the health and safety of others.
9. TRAINING AND CERTIFICATION REQUIREMENTS. Employees shall not be permitted
to engage in routine field activities until they have been trained and certified to a level
commensurate with the degree of anticipated hazards.
a. Basic Level. All employees shall be provided a minimum of 24 hours of health and
safety training prior to their becoming involved in normal, routine field activities. The training
shall include but not be limited to classroom instruction in all the following subject areas:
(1) Employee Rights and Responsibilities;
(2) Nature of Anticipated Hazards;
(3) Emergency Help and Self-Rescue;
(4) Vehicles - Mandatory Rules and Regulations;
(5) Safe Use of Field Equipment;
(6) Use, Handling, Storage, and Transportation of Hazardous Materials;
(7) Personal Protective Equipment and Clothing, Use and Care; and
(8) Safe Sampling Techniques.
In addition to classroom instruction, the employee shall accompany an employee experienced
in field activities and perform actual field tasks for a minimum of three days within a period of
three months after classroom instruction. Employees satisfactorily completing these
requirements will receive certification at the Basic Level of training from the Occupational
Health and Safety Designee at the Reporting Unit.
b. Intermediate Level. All inexperienced employees who are to work with experienced
employees in uncontrolled hazardous waste and hazardous spills sites investigators or
employees engaged in other activities which at a later data are determined by the Director,
Office of Occupational Health and Safety, to present unique hazards requiring additional
training, shall be provided a minimum of 8 hours of additional health and safety training. This
A-4
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Appendix A EPA Order 1440.2
ORDER
1440.2
July 12, 1981
training shall include (in addition to the Basic Level requirements) but not be limited to the
following subject matter:
(1) Site surveillance, observation, and safety plan development;
(2) Use and decontamination of totally enclosed protective clothing and equipment;
(3) Use of field test equipment for radioactivity, explosivity, and other
measurements; and
(4) Topics specific to other identified activities.
In addition to classroom instruction, the employee shall accompany another employee
experienced in hazardous waste and spill site investigations and/or cleanup operations and
perform actual field tasks for a minimum of three days within a three month after classroom
instruction. The employee should also be able to provide on-the-job training and instructions
to inexperienced employees during normal routine field activities (as required above).
Employees satisfactorily completing these requirements will be certified at the Intermediate
Level by the Occupational Health and Safety Designee at the Reporting Unit.
c. Advanced Level. All employees who manage uncontrolled hazardous waste site and
spill site monitoring, sampling, investigations, and cleanup operations shall be provided a
minimum of 8 hours additional health and safety training. The classroom training shall include
but not be limited to (in addition to the Basic and Intermediate Level requirements), instruction
in the following subject areas:
(1) Management of restricted and safe zones;
(2) Rules of Handling the Press and VIP's; and
(3) Safe Use of Specialized Sampling Equipment.
In addition to classroom instruction, the employee shall accompany another employee with
experience in managing hazardous waste and spill site investigations or cleanup operations
and perform actual field tasks for a minimum of three days within a period of three month
period after classroom instruction. After satisfactorily completing these requirements,
employees will receive Advanced Level certification from the Occupational Health and Safety
Designee at the Reporting Unit.
d. General.
(1) An employee may receive certification at the next higher level by completing
only the additional training requirements if certified at the next lower level within the previous
one-year period.
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Appendix A EPA Order 1440.2
1440.2
ORDER
July 12, 1981
(2) The Director, Office of Occupational Health and Safety, may certify employees
based on an evaluation of previous training, education, and experience. Recommendations
for this type certification should be made to the Director by the Occupational Health and
Safety Designee at the Reporting Unit.
10. FREQUENCY OF TRAINING. Employees at the Basic, Intermediate, and Advanced
Levels shall complete a minimum of 8 hours of refresher classroom instruction annually
consisting of a review of all subject areas to maintain their certification. In addition to the
classroom instruction, employees shall have demonstrated by having performed actual field
tasks that they have sufficient practical experience to perform their assigned duties in a safe
and healthful manner.
11. RECORD OF TRAINING.
a. A record of the level of training and certification shall be maintained in the
employee's official personnel file.
b. The Occupational Health and Safety Designee shall maintain a roster of employee
training and certification so that a schedule of annual training can be established.
c. The Occupational Health and Safety Designee shall issue a certificate to the employee
showing the level of training and certification.
12. OCCUPATIONAL MEDICAL MONITORING REQUIREMENTS. All employees routinely
engaged in field activities which present the probability of exposure to hazardous or toxic
substances, which are arduous or physically taxing, or which require the use of respiratory
protective equipment shall be included in the Agency's Occupational Medical Monitoring
Program. Employees should not be permitted to engage in field activities unless they have
undergone a baseline medical examination (as defined in the Agency's Occupational Medical
Monitoring Guidelines), which will show physical fitness and provide a base to measure any
adverse effects their activities may have on these individuals.
13. SAVING PROVISIONS. Changes in the Act, Executive Order, or EPA and OSHA
standards and guidelines which occur after the effective date of this Order will automatically
come under the purview of this Order on the effective date of the change.
Full implementation of this Order shall be within one year of its effective date
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Appendix A
EPA Order 1440.2
ORDER
1440.2
July 12, 1981
Edward J. Hanley
Director, Office of Management
Information and Support Services
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APPENDIX B
SAMPLE SECTION 308 LETTER
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Appendix B Sample Section 308 Letter
Certified Mail—Return Receipt Requested
Date
Dear Sir:
Pursuant to the authority contained in Section 308 of the Clean Water Act (33 U.S.C. 1251
et seq.), representatives of the U.S. Environmental Protection Agency (EPA), or a contractor
retained by EPA, shall conduct, within the next year, a compliance monitoring inspection of
your operations, including associated waste treatment and/or discharge facilities located at
(site of inspection). This inspection will ascertain the degree of compliance with the
requirements of the National Pollutant Discharge Elimination System (NPDES) permit issued
to your organization.
Our representatives may observe your process operations, inspect your monitoring and
laboratory equipment and methods, collect samples, and examine appropriate records, and
they will be concerned with related matters.
In order to facilitate easy access to the plant site, please provide the name of the
responsible facility official who can be contacted upon arrival at the plant. Additionally, we
would appreciate receiving a list of the safety equipment you would recommend that our
representatives have in their possession in order to enter and conduct the inspection safely.
Please provide the information requested within 14 days of receipt of this letter.
If you have any questions concerning this inspection, please call (appropriate designated
official).
Sincerely,
Director
Water Management Division
Sample Section 308 Letter
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APPENDIX C
EPA'S MEMORANDUM ON ENTRY
PROCEDURES
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Appendix C EPA's Memorandum on Entry Procedures
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MEMORANDUM OFFICE OF ENFORCEMENT
TO: Regional Administrators
Surveillance and Analysis Division Directors
Enforcement Division Directors
FROM: Assistant Administrator for Enforcement
SUBJECT: Conduct of Inspections After the Barlow's Decision
I. Summary
This document is intended to provide guidance to the Regions in the conduct of
inspections in light of the recent Supreme Court decision in Marshall v. Barlow's. Inc., U.S._
, 98 S. Ct. 1816 (1978). The decision bears upon the need to obtain warrants or other
process for inspections pursuant to EPA-administered Acts.
In Barlow's, the Supreme Court held that an OSHA inspector was not entitled to enter
the non-public portions of a work site without either (1) the owner's consent, or (2) a warrant.
The decision protects the owner against any penalty or other punishment for insisting upon a
warrant.
In summary, Barlow's should only have a limited effect on EPA enforcement
inspections:
• Inspections will generally continue as usual;
• Where an inspector is refused entry, EPA will seek a warrant through the U.S.
Attorney;
• Sanctions will not be imposed upon owners of establishments who insist on a warrant
before allowing inspections of the non-public portions of an establishment.
The scope of the Barlow's decision is broad. It affects all current inspection programs
of EPA, including inspections conducted by State personnel and by contractors. The
Agency's procedures for inspections, particularly where entry is denied, were largely in accord
with the provisions of Barlow's before the Supreme Court issued its ruling. Nevertheless, a
number of changes in Agency procedure are warranted. Thus, it is important that all
personnel involved in the inspection process be familiar with the procedural guidelines
contained in this document.
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Appendix C EPA's Memorandum on Entry Procedures
This document focuses on the preparation for and conduct of inspections, including (1)
how to proceed when entry is denied, (2) under what circumstances a warrant is necessary,
and (3) what showing is necessary to obtain a warrant.
II. Conduct of Inspections
The following material examines the procedural aspects of conducting inspections
under EPA-administered Acts. Inspections are considered in three stages: (1) preparation for
inspection of premises, (2) entry onto premises, and (3) procedures to be followed where entry
is refused.
A. Preparation
Adequate preparation should include consideration of the following factors
concerning the general nature of warrants and the role of personnel conducting inspections.
(1) Seeking a Warrant Before Inspection
The Barlow's decision recognized that, on occasion, the Agency may wish to obtain
a warrant to conduct an inspection even before there has been any refusal to allow entry.
Such a warrant may be necessary when surprise is particularly crucial to the inspection, or
when a company's prior bad conduct and prior refusals make it likely that warrantless entry
will be refused. Pre-inspection warrants may also be obtained where the distance to a U.S.
Attorney or a magistrate is considerable so that excessive travel time would not be wasted if
entry were denied. At present, the seeking of such a warrant prior to an initial inspection
should be an exceptional circumstance, and should be cleared through Headquarters. If
refusals to allow entry without a warrant increase, such warrants may be sought more
frequently. (For specific instructions on how to obtain a warrant, see Part D.)
(2) Administrative Inspections v. Criminal Investigations
It is particularly important for both inspectors and attorneys to be aware of the
extent to which evidence sought in a civil inspection can be used in a criminal matter, and to
know when it is necessary to secure a criminal rather than a civil search warrant. There are
three basic rules to remember in this regard: (1) If the purpose of the inspection is to discover
and correct, through civil procedures, noncompliance with regulatory requirements, and
administrative inspection (civil) warrant may be used; (2) if the inspection is in fact intended ,
in whole or in part, to gather evidence for a possible criminal prosecution, a criminal search
warrant must be obtained under Rule 41 of the Federal Rules of Criminal Procedure; and (3)
evidence obtained during a valid civil inspection is generally admissible in criminal
proceedings. These principles arise from the recent Supreme Court cases of Marshall v.
Barlow's. Inc.. supra: Michigan v. Tyler. U.S. , 98 S.Ct. 1942 (1978); and U.S. v. LaSalle
National Bank. U.S. , 57 L Ed: 2d 221 (1978). It is not completely clear whether a
combined investigation for civil and criminal violations may be properly conducted under civil
or "administrative" warrant, but we believe a civil warrant can properly be used unless the
intention is clearly to conduct a criminal investigation.
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Appendix C EPA's Memorandum on Entry Procedures
(3) The Use of Contractors to Conduct Inspections
Several programs utilize private contractors to aid in the conduct of inspections.
Since, for the purpose of inspections, these contractors are agents of the Federal government,
the restrictions of the Barlow's decision also apply to them. If contractors are to be
conducting inspections without the presence of actual EPA inspectors, these contractors
should be given training in how to conduct themselves when entry is refused. With respect to
obtaining or executing a warrant, an EPA inspector should always participate in the process,
even if he was not at the inspection where entry was refused.
(4) Inspections Conducted by State Personnel
The Barlow's holding applies to inspections conducted by State personnel and to
joint Federal/State inspections. Because some EPA programs are largely implemented
through the States, it is essential that the Regions assure that State-conducted inspections
are conducted in compliance with the Barlow's decision, and encourage the State inspectors
to consult with their legal advisors when there is a refusal to allow entry for inspection
purposes. State personnel should be encouraged to contact the EPA Regional Enforcement
Office when any questions concerning compliance with Barlow's arise.
With regard to specific procedures for States to follow, the important points to
remember are: (1) The State should not seek forcible entry without a warrant or penalize an
owner for insisting upon a warrant, and (2) the State legal system should provide a
mechanism for issuance of civil administrative inspection warrants. If a State is enforcing an
EPA program through a State statute, the warrant process should be conducted through the
State judicial system. Where a State inspector is acting as a contractor to the Agency, any
refusal to allow entry should be handled as would a refusal to an Agency inspector as
described in section II.B.3. Where a State inspector is acting as a State employee with both
Federal and State credentials, he would utilize State procedures unless the Federal warrant
procedures are more advantageous, in which case, the warrant should be sought under the
general procedures described below. The Regions should also assure that all States which
enforce EPA programs report any denials of entry to the appropriate Headquarters
Enforcement Attorney for the reasons discussed in section II.B.4.
B. Entry
(1) Consensual Entry
One of the assumptions underlying the Court's decision is that most inspections will
be consensual and that the administrative inspection framework will thus not be severely
disrupted. Consequently, inspections will normally continue as before the Barlow's decision
was issued. This means that the inspector will not normally secure a warrant before
undertaking an inspection but, in an attempt to gain admittance, will present his credentials
and issue a notice of inspection where required. The establishment owner may complain
about allowing an inspector to enter or otherwise express his displeasure with EPA or the
Federal government. However, as long as he allows the inspector to enter, the entry is
voluntary and consensual unless the inspector is expressly told to leave the premises. On the
other hand, if the inspector has gained entry in a coercive manner (either in a verbal or
physical sense), the entry would not be consensual.
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Appendix C EPA's Memorandum on Entry Procedures
Consent must be given by the owner of the premises or the person in charge of the
premises at the time of the inspection. In the absence of the owner, the inspector should
make a good faith effort to determine who is in charge of the establishment and present his
credentials to that person. Consent is generally needed only to inspect the non-public
portions of an establishment - i.e., any evidence that an inspector obtains while in an area
open to the public is admissible in an enforcement proceeding.
(2) Withdrawal of Consent
The owner may withdraw his consent to the inspector at any time. The inspection
is valid to the extent to which it has progressed before consent was withdrawn. Thus,
observations by the inspector, including samples and photographs, obtained before consent
was withdrawn, would be admissible in any subsequent enforcement action. Withdrawal of
consent is tantamount to a refusal to allow entry and should be treated as discussed in
section II.B.3. below, unless the inspection had progressed far enough to accomplish its
purposes.
(3) When Entry is Refused
Barlow's clearly establishes that the owner does have the right to ask for a warrant
under normal circumstances.1 Therefore, refusal to allow entry for inspection purposes will
not lead to civil or criminal penalties if the refusal is based on the inspector's lack of warrant
and one of the exemptions discussed in Part C does not apply. If the owner were to allow the
inspector to enter his establishment only in response to a threat of enforcement liability, it is
quite possible that any evidence obtained in such an inspection would be inadmissible. An
inspector may, however, inform the owner who refused entry that he intends to seek a warrant
to compel the inspection. In any event, when entry is refused, the inspector should leave the
premises immediately and telephone the designated Regional Enforcement Attorney as soon
as possible for further instructions. The Regional Enforcement Attorney should contact the
U.S. Attorney's Office for the district in which the establishment desired to be inspected is
located and explain to the appropriate Assistant United States Attorney the need for a warrant
to conduct the particular inspection. The Regional Attorney should arrange for the United
States Attorney to meet with the inspector as soon as possible. The inspector should bring a
copy of the appropriate draft warrant and affidavits. Samples are provided in the appendix to
this document.
(4) Headquarters Notification
It is essential that the Regions keep Headquarters informed of all refusals to allow
entry. The Regional Attorney should inform the appropriate Headquarters Enforcement
Attorney of any refusals to enter and should send a copy of all papers filed to Headquarters.
It is necessary for Headquarters to monitor refusals and Regional success in obtaining
warrants to evaluate the need for improved procedures and to assess the impact of Barlow's
on our compliance monitoring progress.
FIFRA inspections are arguably not subject to this aspect of Barlow's. See discussion, p. 5 and 6.
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Appendix C EPA's Memorandum on Entry Procedures
C. Areas Where a Right of Warrantless Entry Still Exists
(1) Emergency Situations
In an emergency, where there is no time to get a warrant, a warrantless inspection
is permissible. In Camara v. Municipal Court. 387 U.S. 523 (1967), the Supreme Court states
that "nothing we say today is intended to foreclose prompt inspections, even without a
warrant, that the law has traditionally upheld in emergency situations." Nothing stated in
Barlow's indicates any intention by the court to retreat from this position. The Regions will
always have to exercise considerable judgement concerning whether to secure a warrant
when dealing with an emergency situation. However, if entry is refused during and
emergency, the Agency would need the assistance of the U.S. Marshal to gain entry, and a
warrant could probably be obtained during the time necessary to secure that Marshal's
assistance.
An emergency situation would include potential imminent hazard situations, as well
as situations where there is potential for destruction of evidence or where evidence of a
suspected violation may disappear during the time that a warrant is being obtained.
(2) FIFRA Inspection
There are some grounds for interpreting Barlow's as not being applicable to FIFRA
inspections. The Barlow's restrictions do not apply to areas that have been subject to a long
standing and pervasive history of government regulation. An Agency administrative law judge
held recently that even after the Barlow's decision, refusal to allow a warrantless inspection of
a FIFRA regulated establishment properly subjected the owner to civil penalty. N. Jones &
Co.. Inc.. I.F. & R Docket No. III-121C (July 27, 1978). For the present, however, FIFRA
inspections should be conducted under the same requirements applicable to other
enforcement programs.
(3) "Open Fields" and "In Plain View" Situations
Observation by inspectors of things that are in plain view, (i.e., of things that a
member of the public could be in a position to observe) does not required a warrant. Thus, an
inspector's observations from the public area of a plant or even from certain private property
not closed to the public are admissible. Observations made even before presentation of
credentials while on private property which is not normally closed to the public are admissible.
D. Securing a Warrant
There are several general rules for securing warrants. Three documents have to be
drafted: (a) an application for a warrant, (b) an accompanying affidavit, and (c) the warrant
itself. Each document should be captioned with the District Court of jurisdiction, the title of the
action, and the title of the particular document.
The application for a warrant should generally identify the statutes and regulations
under which the Agency is seeking the warrant, and should clearly identify the site or
establishment desired to be inspected (including, if possible, the owner and/or operator of the
site). The application can be a one or two page document if all of the factual background for
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Appendix C EPA's Memorandum on Entry Procedures
seeking the warrant is stated in the affidavit, and the application so states. The application
should be signed by the U.S. Attorney or by his Assistant U.S. Attorney.
The affidavits in support of the warrant application are crucial documents. Each
affidavit should consist of consecutively numbered paragraphs, which describe all of the facts
that support warrant issuance. If the warrant is sought in the absence of probable cause, it
should recite or incorporate the neutral administrative scheme which is the basis for inspecting
the particular establishment. Each affidavit should be signed by someone with personal
knowledge of all the facts stated. In cases where entry has been denied, this person would
most likely be the inspector who was denied entry. Note that an affidavit is a sworn statement
that must either be notarized or personally sworn to before the magistrate.
i
The warrant is a direction to an appropriate official (an EPA inspector, U.S. Marshal
or other Federal officer) to enter a specifically described location and perform specifically
described inspection functions. Since the inspection is limited by the terms of the warrant, it is
important to specify to the broadest extent possible the areas that are intended to be
inspected, any records to be inspected, any samples to be taken, and any articles to be
seized, etc. While a broad warrant may be permissible in civil administrative inspections, a
vague or overly broad warrant will probably not be signed by the magistrate and may prove
susceptible to constitutional challenge. The draft warrant should be ready for the magistrate's
signature at the time of submission via a motion to quash and suppress evidence in Federal
District court. Once the magistrate signs the draft warrant, it is an enforceable document.
Either following the magistrate's signature or on a separate page, the draft warrant should
contain a "return of service" or "certificate of service". This portion of the warrant should
indicate upon whom the warrant was personally served and should be signed and dated by
the inspector. As they are developed, more specific warrant issuance documents will be
drafted and submitted to the Regions.
E. Standards or Bases for the Issuance of Administrative Warrants
The Barlow's decision establishes three standards or bases for the issuance of
administrative warrants. Accordingly, warrants may be obtained upon a showing: 1) of
traditional criminal probable cause, 2) of civil probable cause, or 3) that the establishment was
selected for inspection pursuant to a neutral administrative inspection scheme.
(1) Civil Specific Probable Cause Warrant
Where there is some specific probable cause for issuance of a warrant such as an
employee complaint or competitor's tip, the inspector should be prepared to describe to the
U.S. Attorney in detail the basis for this probable cause.
The basis for probable cause will be stated in the affidavit in support of the warrant.
This warrant should be used when the suspected violation is one that would result in a civil
penalty or other civil action.
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Appendix C EPA's Memorandum on Entry Procedures
(2) Civil Probable Cause Based on a Neutral Administrative Inspection Scheme
Where there is no specific reason to think that a violation has been committed, a
warrant may still be issued if they Agency can show that the establishment is being inspected
pursuant to a neutral administrative scheme. As the Supreme Court stated in Barlow's:
"Probable cause in the criminal law sense is not required. For purposes of an
administrative search, such as this, probable cause justifying the issuance of a
warrant may be based not only on specific evidence of an existing violation, but
also on a showing that "reasonable legislative or administrative standards for
conducting an ... inspection are satisfied with respect to a particular
(establishment)." A warrant showing that a specific business has been chosen
for an OSHA search on the basis of a general administrative plan for the
enforcement of the act derived from neutral sources such as, for example,
dispersion of employees in various type of industries across a given area, and
the desired frequency of searches in any of the lesser divisions of the area,
would protect an employers Fourth Amendment rights.
Every program enforced by the Agency has such a scheme by which it prioritizes and
schedules its inspections. For example, a scheme under which every permit holder in a given
program is inspected on an annual basis is a satisfactory neutral administrative scheme.
Also, a scheme in which one out of ever three known PCB transformer repair shops is
inspected on an annual basis is satisfactory, as long as neutral criteria such as random
selection are used to select the individual establishment to be inspected. Headquarters will
prepare and transmit to the Regions the particular neutral administrative scheme under which
each program's inspections are to be conducted. Inspections not based on specific probable
cause must be based on neutral administrative schemes for a warrant to be issued.
Examples of two neutral administrative schemes are provided in the appendix. (Attachments
II and III)
The Assistant U.S. Attorney will request the inspector to prepare and sign an
affidavit that states the facts as he knows them. The statement should include the sequence
of events culminating in the refusal to allow entry and a recitation of either the specific
probable cause or the neutral administrative scheme which led to the particular
establishment's selection for inspection. The Assistant U.S.'Attorney will then present a
request for an inspection warrant, a suggested warrant, and the inspector's affidavit to a
magistrate or Federal district court judge.2
The Barlow's decision states that imposing the warrant requirement on OSHA would not invalidate warrantless
search provisions in other regulatory statutes since many such statutes already "envision resort to Federal court
enforcement when entry is refused". There is thus some question as to whether the existence of a non-warrant Federal
court enforcement mechanism in a statute requires the use of that mechanism rather than warrant issuance. We believe
that the Barlow's decision gives the Agency the choice of whether to proceed through warrant issuance or through an
application for an injunction, since the decision is largely based on the fact that a warrant procedure imposes virtually no
burden on the inspecting Agency. In addition, any Agency could attempt to secure a warrant prior to inspection on an
ex parte basis, something not available under normal injunction proceedings. Several of the acts enforced by the EPA
Rave provisions allowing the Administrator to seek injunctive relief to assure compliance with the various parts of a
particular statute. There may be instances where it would be more appropriate to seek injunctive relief to gain entry to
a facility than to attempt to secure a warrant for inspection, although at this point we cannot think of any. However, since
the warrant process will be far more expeditious than the seeking of an injunction, any decision to seek such an injunction
for inspection purposes should be cleared through appropriate Headquarters staff.
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Appendix C EPA's Memorandum on Entry Procedures
(3) Criminal Warrants
Where the purpose of the inspection is to gather evidence for a criminal
prosecution, the inspector and the Regional Attorney should request that the U.S. Attorney
seek a criminal warrant under Rule 41 of the Federal Rules of Criminal Procedure. This
requires a specific showing of probable cause to believe that evidence of a crime will be
discovered. Agency policy on the seeking of criminal warrants has not been affected by
Barlow's. The distinction between administrative inspections and criminal warrant situations is
discussed in Section II.A.2.
F. Inspecting with a Warrant
Once the warrant has been issued by the magistrate or judge, the inspector may
proceed to the establishment to commence or continue the inspection. Where there is a high
probability that entry will be refused even with a warrant or where there are threats of
violence, the inspector should be accompanied by a U.S. Marshal when he goes to serve the
warrant on the recalcitrant owner. The inspector should never himself attempt to make any
forceful entry of the establishment. If the owner refuses entry to an inspector holding a
warrant but not accompanied by a U.S. Marshal, the inspector should leave the establishment
and inform the Assistant to the U.S. Attorney and the designated Regional Attorney. They will
take appropriate action such as seeking a citation for contempt. Where the inspector is
accompanied by a U.S. Marshal, the Marshal is principally charged with executing the warrant.
Thus, if refusal or threat to refuse occurs, the inspector should abide by the U.S. Marshal's
decision whether it is to leave, to seek forcible entry, or otherwise.
The inspector should conduct the inspection strictly in accordance with the warrant.
If sampling is authorized, the inspector must be sure to carefully follow all procedures,
including the presentation of receipts for all samples taken. If records or other property are
authorized to be taken, the inspector must receipt thge property taken and maintain an
inventory of anything taken from the premises. This inventory will be examined by the
magistrate to assure that the warrant's authority has not been exceeded.
G. Returning the Warrant
After the inspection has been completed, the warrant must be returned to the
magistrate. Whoever executes the warrant, (i.e., whoever performs the inspection), must sign
the return of service form indicating to whom the warrant was served and the date of service.
He should then return the executed warrant to the U.S. Attorney who will formally return it to
the magistrate or judge. If anything has been physically taken from the premises, such as
records or samples, an inventory of such items must be submitted to the court, and the
inspector must be present to certify that the inventory is accurate and complete.
III. Conclusion
Except for requiring the Agency to formalize its neutral inspection schemes, and for
generally ending the Agency's authority for initiating civil and/or criminal actions for refusal to
allow warrantless inspections, Barlow's should not interfere with EPA enforcement inspections.
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Appendix C EPA's Memorandum on Entry Procedures
Where there is doubt as to how to proceed in any entry case, do not hesitate to call
the respective Headquarters program contact for assistance.
Marvin B. Durning
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APPENDIX D
EPA'S MEMORANDUM AND DEFICIENCY
NOTICE
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Appendix D EPA's Memorandum and Deficiency Notice
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MEMORANDUM OFFICE OF ENFORCEMENT
SUBJECT: "Deficiency Notice" Implementation to Improve Quality Assurance in NPDES
Permittee Self-Monitoring Activities
FROM: Director, Enforcement Division (EN-338)
TO: Enforcement Division Directors, Regions I - X
Surveillance and Analysis Division Directors, Regions I - X
Director, National Enforcement Investigations Center, Denver
The Enforcement Divisions and the Surveillance and Analysis Divisions in several
Regions have developed a form, called a Deficiency Notice, which their inspectors issue at the
end of compliance inspections. This Deficiency Notice alerts NPDES permittees to problems
in their routine self-monitoring activities. On June 11, 1979, the Office of Water Enforcement
proposed that all the Regional offices adopt this form along with the Guidance for its use, and
asked for your comments on this proposal. The Deficiency Notice and Guidance, which are
attached, reflect your comments.
We have ordered the Deficiency Notice Forms, which will be printed on no-carbon-
required paper and will be color coded in pads to correlate with the NPDES Compliance
Inspection Form (EPA 3560-3). You may reproduce the attached form for use until you
receive these forms.
The Deficiency Notice was designed so that State NPDES programs might easily use
it. However, EPA cannot now sanction its use by the States since the Office of Management
and Budget (OMB) has not authorized the form for non-Federal use. We will attempt to get
OMB approval.
Since the Deficiency Notice provides a swift and simple mechanism for responding to
deficiencies in self-monitoring data, I believe that its use will substantially improve the
performance of wastewater treatment facilities without creating additional resource burdens or
enforcement problems. If you have any questions about the Deficiency Notice or its use,
please do not hesitate to call Gary Polvi of my staff at 755-0994.
J. Brian Molloy
Attachments
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Appendix D EPA's Memorandum and Deficiency Notice
DEFICIENCY NOTICE GUIDANCE
Purpose
The purpose for using the Deficiency Notice is to provide a swift and simple method for
improving the quality of data from NPDES self-monitoring activities. Since an inspector may
issue a Deficiency Notice during any NPDES compliance inspection to alert the permittee to
either existing or potential problems in self-monitoring, its receipt prompts the permittee to
quickly take corrective action, as close as possible to the time the inspector perceives the
problem.
The Deficiency Notice is a tool for use in conjunction with any type of EPA NPDES
compliance inspection (i.e., compliance evaluation, sampling, performance audit,
biomonitoring, etc.), during which the inspector identifies problems with self-monitoring that
warrant response.
The Deficiency Notice and Guidance were designed so that State NPDES compliance
monitoring programs could also easily use them. (Note the use of the term "regulatory
authority" throughout this guidance.) However, EPA cannot yet sanction the States' use of
this form because the Office of Management and Budget (OMB) has not yet approved the
form for non-Federal use.
Use of the Deficiency Notice does not apply to a wide range of possible permit
violations. It is to be used by the inspector to alert permittees to deficiencies in their self-
monitoring activities only. The enforcement office of the regulatory authority (i.e., the EPA
Regional Enforcement Division or its State counterpart), not the inspector, will continue to
handle violations relative to compliance schedules or effluent limitations.
Form Description
The Deficiency Notice (see attachment) is one page long and is for use in conjunction
with the standard EPA Compliance Inspection Form (EPA 3560-3 September, 1977). The
reverse side of the Notice contains general instructions to inspectors for completing the form.
The regulatory authority using the form may add other specific instructions that do not conflict
with this guidance.
The form has four sections: (1) basic facility data, (2) deficiencies, (3) comments, and
(4) inspector identification. These sections contain individual spaces where the inspector
during an inspection can log deficiencies in the following self-monitoring activities: (1)
monitoring location, (2) flow measurement, (3) sample collection/holding time, (4) sample
preservation, (5) test procedures, (6) record keeping, (7) other self-monitoring deficiencies
(i.e., sampling frequency, instrument calibration, etc.). Since the existing Compliance
Inspection Form (which inspectors now complete) includes questions and answers relating to
the above seven activities, inspectors should not need much additional time to complete this
Deficiency Notice.
D-2
-------
Appendix D EPA's Memorandum and Deficiency Notice
Administrative Procedures
With few exceptions (see March 7, 1977 EMS Guide), the handling and tracking of
Deficiency Notices will follow the normal EPA Enforcement Management System (EMS)
procedures. Inspectors can issue the Deficiency Notice to a permittee immediately following a
compliance inspection if they discover any permit deficiencies which the Notice includes.
Under unusual circumstances inspectors may delay issuing a Deficiency Notice until after
conferring with other officials of the regulatory authority.
EMS requires the offices responsible for inspections and for NPDES enforcement to
jointly establish a policy delineating the procedure for the permittee to appropriately respond to
the Deficiency Notice. In the EPA Regions, the Directors of the Enforcement Division and the
Surveillance and Analysis (S&A) Division will develop this policy. If the offices agree to allow
the permittee to submit a separate written response rather than to include the response as
part of a regular Discharge Monitoring Report (DMR) submission, they will require the
inspector to record the necessary mailing instructions and deadline for response under the
additional comment section of the Deficiency Notice. The inspector indicates the appropriate
method for the permittee's response in the "requested action" section of the Deficiency Notice.
Due to the nature of most self-monitoring problems it is reasonable for the regulatory authority
to ask that the permittee submit a written description of any corrective actions within 15 work
days after receiving the Notice. Where the permittee is asked to respond as part of a regular
DMR submission, a similar, reporting time allowance should be allotted. In either response
option, the inspector should always indicate in the Deficiency Notice the requested date for
permittee response.
Having the permittee document Deficiency Notice corrective actions as part of a
regular DMR submission establishes accountability for the compliance inspection in the official
NPDES permit compliance file even before a compliance review is undertaken. This is a
resource efficient method of documenting the minimum benefit from performing inspections.
The issuance of a Deficiency Notice is not a formal enforcement action. It is not
intended and must not be construed as an administrative or legal order to the permittee.
Therefore, the action by the permittee to respond is voluntary, but incentive for such response
comes from the positive consideration it may have on further formal enforcement follow-up of
the inspection.
When the regulatory authority receives the permittee's response to the Deficiency
Notice, they will review the inspection data and the permittee's response according to EMS
procedures. If during routine reviews of inspection data, the authorities note deficiencies in
self-monitoring data and note that the inspector did not issue a Deficiency Notice, they may
issue one at any time.
The responsibility for all enforcement activity shall always remain in the
enforcement/compliance review office of the regulatory authority. After agreement between
the Directors of the Regional Enforcement Division and the S&A Division, these offices should
incorporate details for insuring which office retains which responsibility into the Regional EMS.
D-3
-------
Appendix D EPA's Memorandum and Deficiency Notice
Whether or not a Deficiency Notice has been issued, the enforcement office of the regulatory
authority can take administrative or legal action at any time. Also, a Deficiency Notice may
not be appropriate in those cases where additional enforcement action is expected or litigation
against the permittee is already underway.
D-4
-------
Appendix D
EPA's Memorandum and Deficiency Notice
DEFICIENCY NOTICE
NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM (NPDES)
(Read instructions on back of last part before completing)
PERMITTEE (Facility) NAME AND ADDRESS
PERMITTEE REPRESENTATIVE (Receiving this Atof/ce/Title
NPDES PERMIT NO.
During the compliance inspection carried out on (Date)
the deficiencies noted below were found.
Additional areas of deficiency may be brought to your attention following a complete review of the Inspection Report and other in-
formation on file with the REGULATORY AUTHORITY administering your NPDES PERMIT.
DEFICENCIES
MONITORING LOCATION (Describe)
FLOW MEASUREMENT (Describe)
SAMPLE COLLECTION / HOLDING TIME (Describe)
SAMPLE PRESERVATION (Describe)
TEST PROCEDURES SECTION 304(h). 40 CFR 136 (Describe)
RECORD KEEPING (Describe)
OTHER SELF-MONITORING DEFICIENCIES (Describe)
ADDITIONAL COMMENTS
REQUESTED ACTION—Your attention to the correction of the deficiencies noted above is requested. Receipt of a description of the corrective actions
taken will be considered in the determination of the need for further Administrative or Legal Action Your response is to be (Inspector line out inappro-
priate response method): (1) Include with your next NPDES Discharge Monitoring Report (DMR) or (2) submitted as directed by the inspector. Ques-tions
regarding possible follow-up action can be answered by the REGULATORY AUTHORITY to which your DMRs are submitted and which adminis-ters your
NPDES Permit.
INSPECTOR'S SIGNATURE
INSPECTOR'S PRINTED NAME
INSPECTOR'S ADDRESS/PHONE NO
REGULATORY AUTHORITY/ADDRESS
DATE
EPA Form 3560-4 (2-80)
EPA Deficiency Notice Form
D-5
-------
-------
APPENDIX E
NPDES COMPLIANCE INSPECTION REPORT
FORM 3560-3
-------
&EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 10-31-95
Section A: National Data System Coding (i.e., PCS)
Fac Type
Transaction Code NPDES yr/mo/day
1U 2LU 3l I I I I I I I I I11 12I I I I I I l17
Remarks
21 I I I I I I I I I I I I I I I I I I I I I I I II I I I I I I I I I I I I I I I I I I I I 166
Inspection Type
18U
Inspector
19|J
Inspection Work Days
671 I I 169
Facility Self-Monitoring Evaluation Rating
70|_|
81
QA
72
73
74 75I I I I I I I I80
Section B: Facility Data
Name and Location of Facility Inspected (For industrial users discharging to POTW, also
include POTW name and NPDES permit number)
Entry Time/Date Permit Effective Date
Exit Time/Date
Permit Expiration Date
Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
D Yes D No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit
Records/Reports
Facility Site Review
Effluent/Receiving Waters
Flow Measurement
Self-Monitoring Program
Compliance Schedules
Laboratory
Operations & Maintenance
Sludge Handling/Disposal
Pretreatment
Storm Water
CSO/SSO (Sewer Overflow)
Pollution Prevention
Multimedia
Other:
Section D: Summary of Findings/Comments (Attach additional sheets of narrative and checklists as necessary)
Name(s) and Signature(s) of Inspector(s)
Agency/Office/Phone and Fax Numbers
Date
Signature of Management Q A Reviewer
Agency/Office/Phone and Fax Numbers
Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
E-1
-------
INSTRUCTIONS
Section A: National Data System Coding (i.e., PCS)
Column 1: Transaction Code: Use N, C, or D for New, Change, or Delete. All inspections will be new unless there is an error
in the data entered.
Columns 3-11: NPDES Permit No. Enter the facility's NPDES permit number. (Use the Remarks columns to record the State
permit number, if necessary.)
Columns 12-17: Inspection Date. Insert the date entry was made into the facility. Use the year/month/day format (e.g.,
94/06/30 = June 30, 1994).
Column 18: Inspection Type. Use one of the codes listed below to describe the type of inspection:
A Performance Audit L Enforcement Case Support 2 IU Sampling Inspection
B Compliance Biomonitoring M Multimedia 3 IU Non-Sampling Inspection
C Compliance Evaluation (non- P Pretreatment Compliance Inspection 4 IU Toxics Inspection
sampling) R Reconnaissance • 5 IU Sampling Inspection with
D Diagnostic S Compliance Sampling Pretreatment
E Corps of Engineers Inspection U IU Inspection with Pretreatment 6 IU Non-Sampling Inspection with
F Pretreatment Follow-up Audit Pretreatment
Q Pretreatment Audit X Toxics Inspection 7 IU Toxics with Pretreatment
I Industrial User (IU) Inspection Z Sludge
Column 19: Inspector Code. Use one of the codes listed below to describe the lead agency in the inspection.
C — Contractor or Other Inspectors (Specify in Remarks N — NEIC Inspectors
columns) R — EPA Regional Inspector
E — Corps of Engineers S — State Inspector
J - Joint EPA/State Inspectors—EPA Lead T — Joint State/EPA Inspectors-State lead
Column 20: Facility Type. Use one of the codes below to describe the facility.
1 - Municipal. Publicly Owned Treatment Works (POTWs) with 1987 Standard Industrial Code (SIC) 4952.
2 — Industrial. Other than municipal, agricultural, and Federal facilities.
3 — Agricultural. Facilities classified with 1 987 SIC 0111 to 0971.
4 — Federal. Facilities identified as Federal by the EPA Regional Office.
Columns 21-66: Remarks. These columns are reserved for remarks at the discretion of the Region.
Columns 67-69: Inspection Work Days. Estimate the total work effort (to the nearest 0.1 work day), up to 99.9 days, that were
used to complete the inspection and submit a QA reviewed report of findings. This estimate includes the accumulative effort of all
participating inspectors; any effort for laboratory analyses, testing, and remote sensing; and the billed payroll time for travel and
pre and post inspection preparation. This estimate does not require detailed documentation.
Column 70: Facility Evaluation Rating. Use information gathered during the inspection (regardless of inspection type) to evaluate
the quality of the facility self-monitoring program. Grade the program using a scale of 1 to 5 with a score of 5 being used for very
reliable self-monitoring programs, 3 being satisfactory, and 1 being used for very unreliable programs.
Column 71: Biomonitoring Information. Enter D for static testing. Enter F for flow through testing. Enter N for no biomonitoring.
Column 72: Quality Assurance Data Inspection. Cnter Q if the inspection was conducted as followup on quality assurance sample
results. Enter N otherwise.
Columns 73-80: These columns are reserved for regionally defined information.
Section B: Facility Data
This section is self-explanatory except for "Other Facility Data," which may include new information not in the permit or PCS (e.g.,
new outfalls, names of receiving waters, new ownership, and other updates to the record).
Section C: Areas Evaluated During Inspection
Check only those areas evaluated by marking the appropriate box. Use Section D and additional sheets as necessary. Support the
findings, as necessary, in a brief narrative report. Use the headings given on the report form (e.g., Permit, Records/Reports) when
discussing the areas evaluated during the inspection. The heading marked "Multimedia" may indicate medias such as CAA, RCRA,
and TSCA. The heading marked "Other" may indicate activities such as SPCC, BMPs, and concerns that are not covered elsewhere.
Section D: Summary of Findings/Comments
Briefly summarize the inspection findings. This summary should abstract the pertinent inspection findings, not replace the narrative
report. Reference a list of attachments, such as completed checklists taken from the NPDES Compliance Inspection Manuals and
pretreatment guidance documents, including effluent data when sampling has been done. Use extra sheets as necessary.
EPA Form 3560-3 (Rev. 9-94) Reverse
E-2
-------
APPENDIX F
SAMPLE CHAIN-OF-CUSTODY FORM
-------
Appendix F
Sample Chain-of-Custody Form
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Appendix F Sample Chain-of-Custody Form
F-2
-------
APPENDIX G
SUPPLEMENTAL FLOW MEASUREMENT
INFORMATION
-------
Appendix G
SUPPLEMENTAL FLOW
MEASUREMENT INFORMATION
Basic Hydraulic Calculations
The relationship between the flow rate (Q), the average velocity (V), and the cross-sectional
area of the flow (A) is given by the following equation:
Q = VA
where Q = flow in cubic feet per second
V = velocity in feet per second
A = area in square feet.
To convert flow in cubic feet of water per second to flow in gallons of water per minute, the
following proportionality is used:
cubic feet 7.48 gallons water 60 seconds _ gallons
second cubic foot of water minute minute
To convert from cubic feet per second to million gallons per day, multiply the number of cubic
feet per second by 0.6463.
The cross-sectional area (A) of a pipe is described by:
A=1/4jrd2
where d = diameter of the pipe in feet.
Flow Measurement Devices
Flow data may be collected instantaneously or continuously. Instantaneous flows must be
measured when samples are taken so that the pollutant concentrations can be correlated to
flow data. In a continuous flow measurement system, flow measurements are summed to
obtain a value for the total flow to verify NPDES permit compliance.
A typical continuous flow measurement system consists of a flow device, a flow sensor,
transmitting equipment, a recorder, and a totalizer.
G-1
-------
Appendix G Supplemental Flow Measurement Information
Instantaneous flow data can be obtained without using such a system. The primary flow
device is constructed to yield predictable hydraulic responses related to the rate of wastewater
or water flowing through the device. As previously mentioned, examples of such devices
include weirs and flumes, which relate water depth (head) to flow; Venturi meters, which relate
differential pressure to flow; and electromagnetic flowmeters, which relate induced electric
voltage to flow. In most cases, a standard primary flow device has undergone detailed testing
and experimentation and its accuracy has been verified.
Flow is measured by many methods; some are designed to measure open channel flows, and
others are designed to measure flows in pipelines. A complete discussion of all available flow
measurement methods, their supporting theories, and the devices used are beyond the scope
of this manual. The most commonly used flow measurement devices and procedures for
inspecting them will be described briefly in the following paragraphs. For more detail,
inspectors should consult the publications listed in "References" at the end of this chapter.
Primary Devices
Weirs. A weir consists of a thin vertical plate with a sharp crest that is placed in a stream,
channel, or partly filled pipe. Figure G-1 shows a profile of a sharp-crested weir and indicates
the appropriate nomenclature. Four common types of sharp-crested weirs are shown in
Figure G-2. This figure illustrates the difference between suppressed and contracted
rectangular weirs and illustrates Cipolletti (trapezoidal) and V-notch (triangular) weirs.
To determine the flow rate, it is necessary to measure the hydraulic head (height) of water
above the crest of the weir. For accurate flow measurements, the crest must be clean, sharp,
and level. The edge of the crest must not be thicker than 1/8 inch.
The rate of flow over a weir is directly related to the height of the water (head) above the crest
at a point upstream of the weir where the water surface is level. To calculate the discharge
over a weir, the head must first be measured by placing a measuring device upstream of the
weir, at a distance of at least 4 times an approximate measurement of the head. A
measurement can be taken at the weir plate to approximate the head. However, if this
measurement is used to calculate the discharge, this value will provide only a rough estimate
of the discharge.
The head-discharge relationship formulas for nonsubmerged contracted and suppressed
rectangular weirs, Cipolletti weirs, and V-notch weirs are provided in Table G-1. Discharge
rates for the 90-degree V-notch weir (when the head is measured at the weir plate) are
included in Table G-2. Flow rates for 60- and 90-degree V-notch weirs can be determined
from the graph in Figure G-3. Minimum and maximum recommended flow rates for Cipolletti
weirs are provided in Table G-3. Figure G-4 is a nomograph for flow rates for rectangular
weirs using the Francis formulas.
Parshall Flume. The Parshall flume is composed of three sections: a converging upstream
section, a throat or contracted section, and a diverging or dropping downstream section.
When there is free fall out of the throat of a Parshall flume, no diverging downstream section
is required. It operates on the principle that when open channel water flows through a
constriction in the channel, it produces a hydraulic head at a certain point upstream of the
G-2
-------
Appendix G Supplemental Flow Measurement Information
constriction that is proportional to the flow. The hydraulic head is used to calculate the flow.
Flow curves are shown in Figure G-5 to determine free flow through 3 inches to 50 feet
Parshall flumes.
The Parshall flume is good for measuring open channel waste flow because it is self cleaning;
therefore, sand or suspended solids are unlikely to affect the operation of the device. The
flume is both simple and accurate.
The flume size is given by the width of the throat section. Parshall flumes have been
developed with throat widths from 1 inch to 50 feet. The configuration and standard
nomenclature for Parshall flumes are provided in Figure G-6. Strict adherence to all
dimensions is necessary to achieve accurate flow measurements. Figure G-6 provides
Parshall flume dimensions for various throat widths, and Table G-4 provides the minimum and
maximum flow rates for free flow through Parshall flumes.
For free nonsubmerged flow in a Parshall flume of throat and upstream head (Ha in feet), the
discharge relationship for flumes of 8 feet or less is given by the general equation Q =
CWHan, where Q = flow.
Table G-5 provides the values of C, n, and Q for different sizes (widths) of the Parshall
flumes. Nomographs, curves, or tables are readily available to determine the discharge from
head observations.
Flow through a Parshall flume may also be submerged. The degree of submergence is
indicated by the ratio of the downstream head to the upstream head (Hb/Ha), which is the
submergence ratio. Hb is the height of water measured above the crest. The flow is
submerged if the submerged ratio is:
• Greater than 0.5 for flumes under 3 inches
• Greater than 0.6 for flumes 6 to 9 inches
• Greater than 0.7 for flumes 1 to 8 feet
• Greater than 0.8 for flumes larger than 8 feet.
If submerged conditions exist, the inspector should apply a correction factor to the free flow
determined using the relationship Q= CWHn. These correction factors are shown in Figure
G-7 for different sizes of the Parshall flume.
Palmer-Bowlus Flume. The Palmer-Bowlus flume is also composed of three sections: a
converging upstream section, a contracted section or throat, and a diverging downstream
section (Figure G-8). The upstream depth of the water (head) above the raised step in the
throat is related to the discharge rate. The head should be measured at a distance d/2
upstream of the throat where d is the size (width) of the flume. The height of the step is
usually unknown until the manufacturer's data are consulted, it is difficult to manually measure
the height of water above the step at an upstream point. The dimensions for Palmer-Bowlus
flumes are not standardized as they are for Parshall flumes. Therefore, no standard flow
equation exists.- Instead, rating curves are provided by manufacturers of Palmer-Bowlus
flumes to relate the head to the discharge rate.
The flume must be installed with a minimum channel slope downstream to maintain critical
G-3
-------
Appendix G
Supplemental Flow Measurement Information
flow through the flume and prevent the flume from becoming submerged. A small jump or rise
in the water surface below the throat indicates that critical flow through the flume has probably
occurred and submerged conditions do not exist. Accurate flow measurements can usually be
obtained with upstream depths that are up to 95 percent of the pipe diameter. Table G-6
provides a table of the maximum slopes recommended for installation of Palmer-Bowlus
flumes. Advantages of this type of flow measurement device are the following:
• It is easily installed in existing systems.
• Head loss is insignificant.
• Unit is self cleaning.
Venturi Meter. The Venturi (differential pressure) meter is one of the most accurate primary
devices for measuring flow rates in pipes. The Venturi meter is basically a pipe segment
consisting of an inlet section, a converging section, and a throat, along with a diverging outlet
section as illustrated in Figure G-9. The water velocity is increased in the constricted portion
of the inlet section resulting in a decrease in the static pressure. The pressure difference
between the inlet pipe and the throat is proportional to the square of the flow. The pressure
difference can easily be measured very accurately, resulting in an accurate flow
measurement. An advantage of the Venturi meter is that it causes little pressure (head) loss.
The formula for calculating the flow in a Venturi meter is as follows:
Q =
, - h2
(King1963)
where
Q
c
hi
K
volume of water, in cubic feet per second
discharge coefficient, obtain from Table G-7. C varies with Reynold's
number, meter surfaces, and installation
pressure head at center of pipe at inlet section, in feet of water h2 =
pressure head at throat, in feet of water
constant which relates d2 to d1 for Venturi meters. Obtain values of K
from Table G-8 or calculate according to the formula
where
K =
\
2g
1 -
-1
d1 J
throat diameter, in feet
diameter of inlet pipe, in feet
Electromagnetic Flowmeter. The electromagnetic flowmeter operates according to Faraday's
Law of Induction: the voltage induced by a conductor moving at right angles through a
magnetic field will be proportional to the velocity of the conductor through the field. In the
electromagnetic flowmeter, the conductor is the liquid stream to be measured and the field is
produced by a set of electromagnetic coils. A typical electromagnetic flowmeter is shown in
Figure G-10. The induced voltage is transmitted to a converter for signal conditioning. The
G-4
-------
Appendix G Supplemental Flow Measurement Information
meter may be provided with recorder and totalizer using electric or pneumatic transmission
systems. This type of flowmeter is useful at sewage lift stations and for measuring total raw
wastewater flow or raw or recirculated sludge flow.
Electromagnetic flowmeters are used in full pipes and have many advantages, including:
accuracies of +1 percent, a wide flow measurement range, a negligible pressure loss, no
moving parts, and rapid response time. However, they are expensive and buildup of grease
deposits or pitting by abrasive wastewaters can cause error. Regular checking and cleaning
of the electrodes is necessary. The meter electronics can be checked for proper operation
with devices specially made for this purpose. The meter should be checked at least annually.
The calibration of an electromagnetic flowmeter cannot be verified except by returning it to the
factory or by the dye dilution method.
Propeller Meter. The propeller meter (Figure G-11) operates on the principle that liquid hitting
the propeller will cause the propeller to rotate at a speed proportional to the flow rate. The
meter is self-contained and requires no energy or equipment other than a mechanical totalizer
to obtain a cumulative flow reading. Equipment may be added to the meter to produce a flow
reading, to pace chemical feed equipment, and to control telemetering equipment for remote
readout. The calibration of a propeller meter can be checked by returning it to the factory, by
comparing its readings to another meter measuring the same flow, or by using the dye dilution
method.
Secondary Devices
Secondary devices are the devices in the flow measurement system that translate the
interaction of primary devices in contact with the fluid into the desired records or readout.
They can be organized into two broad classes:
• Nonrecording type with direct readout (e.g., a staff gauge) or indirect readout from
fixed points (e.g., a chain, wire weight, float)
• Recording type with either digital or graphic recorders (e.g., float in well, float in flow,
bubbler, electrical, acoustic).
The advantages and disadvantages of various secondary devices are provided in Table G-9.
Some wastewater facilities may need to measure flow by means of pumps in which
discharge-versus-power relationships have been determined from measurements of the
average output or input during a period in which discharge measurements were made.
Suitable curves may be developed from these test data. When readily available from the
manufacturer, pump curves may be used by the inspector to estimate flow.
Because of wear on pumps and uncertainty regarding actual discharge heads, pump curves at
best only provide an estimate of the flow. Pump curves are not normally accurate enough to
be used for NPDES permit discharge flow measurements. Pump curves have been used for
G-5
-------
Appendix G Supplemental Flow Measurement Information
determining large flows, such as the cooling water discharge from large steam electric power
plants, where a high degree of accuracy was not necessary.
G-6
-------
Appendix G
Supplemental Flow Measurement Information
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G-7
-------
Appendix G
Supplemental Flow Measurement Information
Table G-2
Discharge of 90° V-Notch Weir—Head Measured at Weir Plate
Head®
Weir
in Feet
0.06
0.07
0.08
0.09
0.10
0.11
0.12
0.13
0.14
0.15
0.16
0.17
0.18
0.19
0.20
0.21
0.22
0.23
0.24
0.25
0.26
0.27
0.28
0.29
0.30
0.31
0.32
0.33
0.34
0.35
0.36
0.37
0.38
0.39
0.40
0.41
0.42
0.43
0.44
0.45
Equation Q = 3.01
Flow
Rate
inCFS
0.003
0.004
0.006
0.008
0.010
0.013
0.016
0.019
0.023
0.027
0.032
0.037
0.043
0.049
0.056
0.063
0.070
0.079
0.087
0.097
0.107
0.117
0.128
0.140
0.152
0.165
0.178
0.193
0.207
0.223
0.239
0.256
0.273
0.291
0.310
0.330
0.350
0.371
0.393
0.415
Hw248(where Hw,
Head®
Weir
in Feet
0.46
0.47
0.48
0.49
0.50
0.51
0.52
0.53
0.54
0.55
0.56
0.57
0.58
0.59
0.60
0.61
0.62
0.63
0.64
0.65
0.66
0.67
0.68
0.69
0.70
0.71
0.72
0.73
0.74
0.75
0.76
0.77
0.78
0.79
0.80
0.81
0.82
0.83
0.84
0.85
head, is in
Flow
Rate
inCFS
0.439
0.463
0.488
0.513
0.540
0.567
0.595
0.623
0.653
0.683
0.715
0.747
0.780
0.813
0.848
0.883
0.920
0.957
0.995
1.034
1.074
1.115
1.157
1.199
1.243
1.287
1.333
1.379
1.426
1.475
1.524
1.574
1.625
1.678
1.730
1.785
1.840
1.896
1.953
2.012
feet at the weir and
Head®
Weir
in Feet
0.86
0.87
0.88
0.89
0.90
0.91
0.92
0.93
0.94
0.95
0.96
0.97
0.98
0.99
1.00
1.01
1.02
1.03
1.04
1.05
1.06
1.07
1.08
1.09
1.10
1.11
1.12
1.13
1.14
1.15
1.16
1.17
1.18
1.19
1.20
1.21
1.22
1.23
1.24
1.25
Q is in cubic feet
Flow
Rate
inCFS
2.071
2.140
2.192
2.255
2.318
2.382
2.448
2.514
2.582
2.650
2.720
2.791
2.863
2.936
3.010
3.085
3.162
3.239
3.317
3.397
3.478
3.556
3.643
3.727
3.813
3.889
3.987
4.076
4.166
4.257
4.349
4.443
4.538
4.634
4.731
4.829
4.929
5.030
5.132
5.235
per second.
G-8
-------
Appendix G
Supplemental Flow Measurement Information
Table G-3
Minimum and Maximum Recommended Flow Rates
for Cipolletti Weirs
Crest
Length, ft.
1
1.5
2
2.5
3
4
5
6
8
10
Minimum
Head, ft.
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
Minimum Flow Rate
MGD
0.195
0.292
0.389
0.487
0.584
0.778
0.973
0.17
0.56
1.95
CFS
0.301
0.452
0.602
0.753
0.903
1.20
1.51
1.81
2.41
3.01
Maximum
Head, ft.
0.5
0.75
1.0
1.25
1.5
2.0
2.5
3.0
4.0
5.0
Maximum Flow Rate
MGD
0.769
2.12
4.35
7.60
12.0
24.6
43.0
67.8
139.0
243.0
CFS
1.19
3.28
6.73
11.8
18.6
38.1
66.5
105.0
214.0
375.0
Table G-4
Minimum and Maximum Recommended Flow Rates
for Free Flow Through Parshall Flumes
Throat
Width,
W
1 in.
2 in.
3 in.
6 in.
9 in.
1 ft.
1.5 ft.
2 ft.
3 ft.
4 ft.
5 ft.
6 ft.
8 ft.
10 ft.
12 ft.
Minimum
Head, ft.
0.07
0.07
0.10
0.10
0.10
0.10
0.10
0.15
0.15
0.20
0.20
0.25
0.25
0.30
0.33
Minimum Flow Rate
MGD
0.003
0.007
0.018
0.035
0.05
0.078
0.112
0.273
0.397
0.816
1.00
1.70
2.23
3.71
5.13
CFS
0.005
0.011
0.028
0.054
0.091
0.120
0.174
0.423
0.615
1.26
1.55
2.63
3.45
5.74
7.93
Maximum
Head, ft.
0.60
0.60
1.5
1.5
2.0
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
3.5
4.5
Maximum Flow Rate
MGD
0.099
0.198
1.20
2.53
5.73
10.4
15.9
21.4
32.6
43.9
55.3
66.9
90.1
189
335
CFS
0.153
0.306
1.86
3.91
8.87
16.1
24.6
33.1
50.4
67.9
85.6
103
139
292
519
G-9
-------
Appendix G
Supplemental Flow Measurement Information
Table G-5
Free-Flow Values of C and N for Parshall Flumes
Based on the Relationship Q = CWH"
(American Petroleum Institute 1969)
Flume Throat, W
1
2
3
6
9
1
1.5
2
3
4
5
6
7
8
in.
in.
in.
in.
in.
ft.
ft.
ft.
ft.
ft.
ft.
ft.
ft.
ft.
C
0.338
0.676
0.992
2.06
3.07
4W*
4W*
4W*
4W*
4W*
4W*
4W*
4W*
4W*
n
1.55
1.55
1.55
1.58
1.53 -
1.522W0'026
1 .522W0'026
1.522W0'026
1.522W0'026
1.522W0026
1.522W0'026
1.522W0026
1.522W0026
1.522W0'026
Max. Q CFS
0.15
0.30
1.8
3.9
8.9
16.1
24.6
33.1
50.4
67.9
85.6
103.5
121.4
139.5
Where W
Q
C
H
n
Flume throat width
Flow (CFS)
Constant
Head upstream of the flume throat (feet)
Constant
W should be represented in feet to calculate C
G-10
-------
Appendix G
Supplemental Flow Measurement Information
Table G-6
Minimum and Maximum Recommended Flow Rates for
Free Flow Through Plasti-Fab Palmer-Bowlus Flumes
D Flume
Size (in.)
6
8
10
12
15
18
21
24
27
30
Maximum
Slope for
Upstream (%)
2.2
2.0
1.8
1.6
1.5
1.4
1.4
1.3
1.3
1.3
Minimum
Head (ft.)
0.11
0.15
0.18
0.22
0.27
0.33
0.38
0.44
0.49
0.55
Minimum Flow
Rate
MGD
0.023
0.048
0.079
0.128
0.216
0.355
0.504
0.721
0.945
1.26
CFS
0.035
0.074
0.122
0.198
0.334
0.549
0.780
1.12
1.46
1.95
Maximum
Head (ft.)
0.36
0.49
0.61
0.73
0.91
1.09
1.28
1.46
1.64
1.82
Maximum Flow
Rate
MGD
0.203
0.433
0.752
1.18
2.06
3.24
4.81
6.70
8.95
11.6
CFS
0.315
0.670
1.16
1.83
3.18
5.01
7.44
10.4
13.8
18.0
G-11
-------
Appendix G
Supplemental Flow Measurement Information
Table G-7
Coefficients of Discharge c for Venturi Meters
(King 1963)
Diameter of
Throat, in.
1
2
4
8
12
18
48
Throat Velocity, ft. per sec.
3
0.935
0.939
0.943
0.948
0.955
0.963
0.970
4
0.945
0.948
0.952
0.957
0.962
0.969
0.977
5
0.949
0.953
0.957
0.962
0.967
0.973
0.980
10
0.958
0.965
0.970
0.974
0.978
0.981
0.984
15
0.963
0.970
0.975
0.978
0.981
0.983
0.985
20
0.966
0.973
0.977
0.980
0.982
0.984
0.986
30
0.969
0.974
0.978
0.981
0.983
0.985
0.987
40
0.970
0.975
0.979
0.982
0.984
0.986
0.988
50
0.972
0.977
0.980
0.983
0.985
0.986
0.988
Table G-8
Values of K in Formula for Venturi Meters
(King 1963)
d2
d1
0.20
0.21
0.22
0.23
0.24
0.25
0.26
0.27
0.28
0.29
0.30
0.31
0.32
K
6.31
6.31
6.31
6.31
6.31
6.31
6.31
6.32
6.32
6.32
6.33
6.33
6.33
d2
d1
0.33
0.34
0.35
0.36
0.37
0.38
0.39
0.40
0.41
0.42
0.43
0.44
0.45
K
6.34
6.34
6.35
6.35
6.36
6.37
6.37
6.38
6.39
6.40
6.41
6.42
6.43
d2
d1
0.46
0.47
0.48
0.49
0.50
0.51
0.52
0.53
0.54
0.55
0.56
0.57
0.58 .
K
6.45
6.46
6.47
6.49
6.51
6.52
6.54
6.54
6.59
6.61
6.64
6.66
6.69
d2
d1
0.59
0.60
0.61
0.62
0.63
0.64
0.65
0.66
0.67
0.68
0.69
0.70
0.71
K
6.72
6.75
6.79
6.82
6.86
6.91
6.95
7.00
7.05
7.11
7.17
7.23
7.30
d2
d1
0.72
0.73
0.74
0.75
0.76
0.77
0.78
0.79
0.80
0.81
0.82
0.83
0.84
K
7.37
7.45
7.53
7.62
7.72
7.82
7.94
8.06
8.20
8.35
8.51
8.69
8.89
G-12
-------
Appendix G
Supplemental Flow Measurement Information
Table G-9
Advantages and Disadvantages of Secondary Devices
Device
Advantages
Disadvantages
Hook Gauge
Stage Board
Pressure
Measurement
a. Pressure Bulb
b. Bubbler Tube
Float
Dipper
Ultrasonic
Common
Common
Since no compressed air is used,
source can be linked directly to
sampler
Self-cleaning, less expensive,
reliable
Inexpensive, reliable
Quite reliable, easy to operate
No electrical or mechanical
contact
Requires training to use, easily
damaged
Needs regular cleaning, difficult to
read top of meniscus
Openings can clog, expensive
Needs compressed air or other air
source
Catches debris, requires frequent
cleaning to prevent sticking and
changing buoyancy, and corroding
hinges
Oil and grease foul probe, causing
possible sensor loss
Errors from heavy turbulence and
foam, calibration procedure is more
involved than for other devices
G-13
-------
Appendix G
Supplemental Flow Measurement Information
Figure G-1
Profile and Nomenclature of Sharp-Crested Weirs
(Associated Water and Air Resource Engineers, Inc., 1973)
20 H
Point to
Measure
Depth, H
max
K=Approx. 0.1" «
or
\ /
Sharp-Crested Weir
Weir Crest
Approx.
2"
I \ v.
Minimum
Discharge
Level for
Free Fall
Free Fall
Weir
461B-05
G-15
-------
Appendix G
Supplemental Flow Measurement Information
Figure G-2
Three Common Types of Sharp-Crested Weirs
(Associated Water and Air Resource Engineers, Inc., 1973)
Crest Length
Con.r.c.ion,)
2Hmax
Minimum Crest Length
Trapezoidal (Cipolletti) Sharp-Crested Weir
2 Hmax
Minimum Crest Length
Contracted (With End Contractions)
Rectangular Weir
2 Hmax
Minimum
V-Notch (Triangular) Sharp-Crested Weir
461B-06
G-16
-------
Appendix G
Supplemental Flow Measurement Information
Figure G-3
Flow Rates for 60° and 90° V-Notch Weirs
(Associated Water and Resource Engineers, Inc., 1973)
24—
•=_
—
—
20-
18-E
16-
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= °
E *°
=• 200 k.^
- l^k
- mjj^
=•100 |
=•80 5
«• o
_ o
-60
-------
Appendix G
Supplemental Flow Measurement Information
Figure G-4
Nomograph for Capacity of Rectangular Weirs
(Associated Water and Air Resource Engineers,
1.0
1
i .u
2.0
2.5
3.0
4.0
5.0
6.0
7.0
8.0
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15.0
20.0
25.0
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461B-09
G-18
-------
Appendix G
Supplemental Flow Measurement Information
Figure G-5
Flow Curves for Parshall Flumes
(Associated Water and Air Resource Engineers, Inc., 1973)
GPM
1,000,000
800,000
600,000
500,000
400,000
300,000
200,000
100,000
80,000
60,000
50,000
40,000
30,000
20,000
10,000
8,000
6,000
5,000
4,000
3,000
2,000
GPM
1,000
800
600
500
400
300
200
100
80
60
50
40
30
20
Flow
10
8
MGD
3000
2000
1000
800
600
500
400
300
200
100
80
60
50
40
30
20
10
8
6
5
4
3
2
10
08
06
05
04
03
02
MGD
01
0.08
8:8i!
0.04
Flow
0.02
1
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Flow
461B-10
Five inches is minimum
full scale head with Foxboro
float and cable meter
Thirty-six inches is maximum
full scale head with Foxboro
float and cable meter
G-19
-------
Appendix G
Supplemental Flow Measurement Information
Figure G-6
Dimensions and Capacities of Parshall Measuring Flumes for Various Throat Widths
(Associated Water and Air Resource Engineers, Inc., 1973)
S\oPe
— Zero Reference
Level for Ha
and Hb
461B-07
G-20
-------
Appendix G
Supplemental Flow Measurement Information
Figure G-6
Dimensions and Capacities of Parshall Measuring
(Continued)
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-------
Appendix G
Supplemental Flow Measurement Information
Figure G-7
Effect of Submergence on Parshall Flume Free Discharge
(Civil Engineering, ASCE)
100
50
70 80
Hb
Submergence, HQ, in Percent
90 100
461B-11
G-22
-------
Appendix G
Supplemental Flow Measurement Information
Figure G-8
Free-Flowing Palmer-Bowlus Flume
Upper
Transition
Lower
Transition
Flow
Small Jump
Should Occur
in This Region
Upstream
Depth
Preferred Head
Measuring Point
D = Conduit Diameter
Downstream
Depth
T
Pipe
Diameter
Figure G-9
Configuration and Nomenclature of Venturi Meter
Inlet Section
Throat
Section
Outlet Section
Low Pressure Tap
461B-12
G-23
-------
Appendix G
Supplemental Flow Measurement Information
Flow
Figure G-10
Electromagnetic Flowmeter
Insulating Liner
Electrode Assembly
Steel Meter Body
Magnet Coils
Potting Compound
Figure G-11
Propeller Flowmeter
Reduction Gears
Direct Reading Totalizer
Straightening Propeller Bevel Gears
Vanes
461B-13
G-24
-------
APPENDIX H
RECOMMENDED EFFLUENT
TOXICITY TEST CONDITIONS
-------
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-1
Summary of Recommended Test Conditions for Sheepshead Minnow
(Cyprinodon variegatus) Larval Survival and Growth Test
1. Test type:
2. Salinity:
3. Temperature:
4. Light quality:
5. Light intensity:
6. Photoperiod:
7. Test chamber size:
8. Test solution volume:
9. Renewal of test concentrations:
10. Age of test organisms:
11. Larvae/test chamber:
12. Replicate chambers/concentration:
13. Source of food:
14. Feeding regime:
15. Cleaning:
16. Aeration:
17. Dilution water:
Static renewal
20 °/oo to 32 °/oo + 2 7oo
25 ± 2°C
Ambient laboratory illumination
10-20 uE/m2/s (50-100 ft-c) (ambient lab
levels)
14 h light, 10 h darkness
300 mL - 1 L beakers or equivalent
250 - 750 mL/replicate (loading and DO
restrictions must be met)
Daily
Newly hatched larvae (less than 24 h old)
15 larvae/chamber (minimum of 10)
4 (minimum of 3)
Newly hatched Artemia) nauplii (less than 24
hold)
Feed once a day 0.10 g wet weight Artemia
nauplii per replicate on Days 0-2; feed 0.15
g wet weight Artemia nauplii per replicate on
Days 3-6
Siphon daily, immediately before test
solution renewal
None, unless DO falls below 60% of
saturation, then aerate all chambers. Rate
should be less than 100 bubbles/min.
Uncontaminated source of natural seawater,
or hypersaline brine or artificial seawater
mixed with deionized water
H-1
-------
Appendix H Recommended Effluent Toxicity Test Conditions
Table H-1
Summary of Recommended Test Conditions for Sheepshead Minnow
(Cyprinodon variegatus) Larval Survival and Growth Test (Continued)
18. Effluent concentrations: 5 and a control
19. Dilution factor: Approximately 0.3 or 0.5
20. Test duration: 7 days
21. Effects measured: Survival and growth (weight)
H-2
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-2
Summary of Recommended Test Conditions for Sheepshead Minnow
(Cyprinodon variegatus) Embryo Larval Survival and Teratogenicity Test
1. Test type:
2. Salinity:
3. Temperature:
4. Light quality:
5. Light intensity:
6. Photoperiod:
7. Test chamber size:
8. Test solution volume:
9. Renewal of test concentration:
10. Age of test organisms:
11. No. of embryos/chamber:
12. Replicate test chambers/ concentration:
13. Embryos per concentration:
14. Feeding regime:
15. Aeration:
16. Dilution water:
17. Effluent test concentrations:
18. Dilution factor:
19. Test duration:
20. Effects measured:
Static renewal
5 °/oo to 32 °/oo ± 2 °/oo
25 ± 2°C
Ambient laboratory light
10-20 uE/m2/s, or 50-100 ft-c (ambient
laboratory levels)
14 h light, 10 h darkness
500 mL
400 mL (minimum of 250 mL)
Daily
less than 24 h old
15 (minimum of 10)
4 (minimum of 3)
60 (minimum of 30)
Feeding not required
None unless DO falls below 60% saturation
Uncontaminated source of sea water;
deionized water mixed with artificial sea
salts, or hypersaline brine
5 and a control
Approximately 0.3 or 0.5
9 days
Percent hatch; percent larvae dead or with
debilitating morphological and/or behavior
abnormalities such as: gross deformities;
curved spine; disoriented, abnormal
swimming behavior; surviving normal larvae
from original embryos
H-3
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-3
Summary of Recommended Test Conditions for the Inland Silverside
(Menidia beryllina) Larval Survival and Growth Test
1. Test type:
2. Salinity:
3. Temperature:
4. Light quality:
5. Light intensity:
6. Photoperiod:
7. Test chamber size:
8. Test solution volume:
9. Renewal of test concentrations:
10. Age of test organisms:
11. Larvae/test chamber and control:
12. Replicate chambers/concentration:
13. Source of food:
14. Feeding regime:
15. Cleaning:
16. Aeration:
17. Dilution water:
Static renewal
5 °/oo to 32 °/oo (± 2 °/oo of the selected
test salinity)
25 + 2°C
Ambient laboratory illumination
10-20 uE/m2/s (50-100 ft-c) (ambient lab
levels)
14 h light, 10 h darkness
300 mL - 1 L containers
250 - 750 mL/replicate (loading and DO
restrictions must be met)
Daily
7-11 days post hatch
15 (minimum of 10)
4 (minimum of 3)
Newly hatched Artemia nauplii
Feed 0.10 g wet weight Artemia nauplii per
replicate on days 0-2; feed 0.15 g wet
weight Artemia nauplii per replicate on days
3-6
Siphon daily, immediately before test
solution renewal and feeding
None, unless DO concentration falls below
60% of saturation, then aerate all chambers.
Rate should be less than 100 bubbles/min.
Uncontaminated source of sea water or
deionized water mixed with hypersaline
brine.
H-4
-------
Appendix H Recommended Effluent Toxicity Test Conditions
Table H-3
Summary of Recommended Test Conditions for the Inland Silverside
(Menidia beryllina) Larval Survival and Growth Test (Continued)
18. Effluent concentrations: At least 5 and a control
19. Dilution factor: Approximately 0.3 or 0.5
20. Test duration: 7 days
21. Effects measured: Survival and growth (weight)
H-5
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-4
Summary of Recommended Test Conditions for Mysidopsis bahia
7-Day Survival, Growth, and Fecundity Test
1. Test type:
2. Salinity:
3. Temperature:
4. Photoperiod
5. Light intensity:
6. Test chamber:
7. Test solution volume:
8. Renewal of test solutions:
9. Age of test organisms:
10. Number of treatments per study:
11. Number of organisms per test chamber:
12. Number of replicate chambers per
treatment:
13. Source of food:
14. Feeding regime:
15. Aeration:
16. Dilution water:
17. Test duration:
18. Dilution factor:
19. Effects measured:
20. Cleaning:
Static renewal
20 7oo to 32 °/oo ± 2 °/oo
26 ± 27°C
16 h light, 8 h dark, with phase in/out period
10-20 uE/m2/s (50-100 ft.-c.)
8 oz plastic disposable cups, or 400 mL
glass beakers
150 mL per replicate cup
Daily
7 days
Minimum of 5 treatments and a control
5
8
Artemia nauplii
»
Feed 150 24-h old nauplii per mysid daily,
half after test solution renewal and half after
8- 12 h.
None unless DO falls below 60% saturation,
then gently in all cups
Natural sea water or hypersaline brine
7 days
Survival, growth, and egg development
Approximately 0.3 or 0.5
Pipette excess food from cups daily
H-6
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-5
Summary of Recommended Effluent Toxicity Test Conditions for the Fathead Minnow
Pimephales promelas Larval Survival and Growth Test
1. Test type:
3. Temperature(°C):
3. Light quality:
4. Light intensity:
5. Photoperiod:
6. Test chamber size:
7. Test solution volume:
8. Renewal of test concentrations:
9. Age of test organisms:
10. No. larvae per test chamber:
11. No. replicate chambers per
concentration:
12. No. larvae per concentration:
13. Feeding regime:
14. Cleaning:
15. Aeration:
16. Dilution water:
Static renewal
25±1°C
Ambient laboratory illumination
10-20 uE/m2/s (50-100 ft-c) (ambient
laboratory levels)
16 h light, 8 h darkness
500 mL
250 mL/replicate
Daily
Newly hatched larvae less than 24 h old
15 (minimum of 10)
4 (minimum of 3)
60 (minimum of 30)
Feed 0.1 mL newly hatched (less than 24-h
old) brine shrimp nauplii three times daily at
4-h intervals or, as a minimum, 0.15 mL
twice daily, 6 h between feedings (at the
beginning of the work day prior to renewal,
and at the end of the work day following
renewal). Sufficient larvae are added to
provide an excess. Larvae are not fed
during the final 12 h of the test
Siphon daily, immediately before test
solution renewal
None, unless DO concentration falls below
40% saturation. Rate should not exceed
100 bubbles/min
Moderately hard synthetic water is prepared
using MILLIPORE MILLI-QR or equivalent
deionized water and reagent grade
chemicals or 20% DMW (see Section 7)
H-7
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-5
Summary of Recommended Effluent Toxicity Test Conditions for the Fathead Minnow
Pimephales promelas Larval Survival and Growth Test (Continued)
17. Effluent concentrations:
18. Dilution factor:1
19. Test duration:
20. Endpoints:
21. Test acceptability:
22. Sampling requirement:
23. Sample volume required:
Minimum of 5 and a control
Approximately 0.3 or 0.5
7 days
Survival and growth (weight)
80% or greater survival in controls; Average
dry weight of surviving controls equals or
exceeds 0.25 mg
For on-site tests, samples are collected
daily, and used with 24 h of the time they
are removed from the sampling device. For
off-site tests, a minimum of three samples
are collected, and used as described in
Paragraph 11.7.1
2.5 Uday
1 Surface water test samples are used as collected (undiluted).
H-8
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-6
Summary of Recommended Effluent Toxicity Test Conditions for the Fathead Minnow
Pimephales promelas Embryo-Larval Survival and Teratogenicity Test
1. Test type:
2. Temperature:
3. Light quality:
4. Light intensity:
5. Photoperiod:
6. Test chamber size:
7. Test solution volume:
8. Renewal of test concentration:
9. Age of test organisms:
10. No. embryos per test chamber:
11. No. replicate test chambers per
concentration:
12. No. embryos per concentration:
13. Feeding regime:
14. Aeration:
15. Dilution water:
16. Effluent test concentrations:
17. Dilution factor1
18. Test duration:
Static renewal
25±1°C
Ambient laboratory illumination
10-20 uE/m2/s 50-100 ft-c (ambient
laboratory levels)
16 h light, 8 h darkness
150-500 mL
70-200 mL
Daily
Less than 36-h old embryos
15 (minimum of 10)
4 (minimum of 3)
60 (minimum of 30)
Feeding not required
None unless DO falls below 40% saturation
Moderately hard synthetic water is prepared
using MILLIPORE MILLI-QR or equivalent
deionized water and reagent grade
chemicals or 20% DMW (see Section 7).
The hardness of the test solutions must
equal or exceed 25 mg/L (CaCO3) to ensure
hatching.
5 and a control
Approximately 0.3 or 0.5
7 days
1 Surface water test samples are used as collected (undiluted).
H-9
-------
Appendix H Recommended Effluent Toxicity Test Conditions
Table H-6
Summary of Recommended Effluent Toxicity Test Conditions for the Fathead Minnow
Pimephales promelas Embryo-Larval Survival and Teratogenicity Test (Continued)
19. Endpoint: Combined mortality (dead and deformed
organisms)
20. Test acceptability: 80% or greater survival in controls
21. Sampling requirement: For on-site tests, samples are collected daily
and used within 24 h of the time they are
removed from the sampling device. For off-
site tests a minimum of three samples are
collected and used as described in
Paragraph 11.7.1.
22. Sample volume required: 2.5 L/day
H-10
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-7
Summary of Recommended Effluent Toxicity Test Conditions
for the Ceriodaphia Survival and Reproduction Test
1. Test type:
2. Temperature(°C):
3. Light quality:
4. Light intensity:
5. Photoperiod:
6. Test chamber size:
7. Test solution volume:
8. Renewal of test solutions:
9. Age of test organisms:
10. No. neonates per test chamber:
11. No. replicate test chambers per
concentration:
12. No. neonates per test concentration:
13. Feeding regime:
14. Aeration:
15. Dilution water:
16. Effluent concentrations:
17. Dilution factor1
18. Test duration:
Static renewal
25±1°C
Ambient laboratory illumination
10-20 uE/m2/s 50-100 tt-c (ambient lab
levels)
16 h light, 8 h darkness
30 mL
15 mL
Daily
Less than 24 h; and all released within a 8-h
period
1
10
10
Feed 0.1 mL each of YCT and algal
suspension per test chamber daily.
None
•
Moderately hard synthetic water is prepared
using MILLIPORE MILLI-QR or equivalent
deionized water and reagent grade
chemicals or 20% DMW (see Section 7).
Minimum of 5 effluent concentrations and a
control.
Approximately 0.3 or 0.5
Until 60% of control females have three
broods (may require more or less than 7
days).
1 Surface water test samples are used undiluted.
H-11
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-7
Summary of Recommended Effluent Toxicity Test Conditions
for the Ceriodaphia Survival and Reproduction Test (Continued)
19. Endpoints:
20. Test acceptability:
21. Sampling requirements:
22. Sample volume required:
Survival and reproduction
80% or greater survival and an average of
15 or more young/surviving female in the
control solutions. At least 60% of surviving
females in controls should have produced
their third brood.
For on-site tests, samples are collected
daily, and used within 24 h of the time they
are removed from the sampling device. For
off-site tests, a minimum of three samples
are collected, and used as described in
Paragraph 12.6.1.
1 L
H-12
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-8
Summary of Recommended Effluent Toxicity Test Conditions
for the Algal (Selenastrum capricornutum) Growth Test
1. Test type:
2. Temperature:
3. Light quality:
4. Light intensity:
5. Photoperiod:
6. Test chamber size:
7. Test solution volume:
8. Renewal of test solutions:
9. Age of test organisms:
10. Initial cell density in test chambers:
11. No. replicate chambers/concentration:
12. Shaking rate:
13. Dilution water:
14. Effluent concentrations:
15. Dilution factor1:
16. Test duration:
17. Endpoint:
18. Test acceptability:
19. Sample volume required:
Static
25±1°C
"Cool white" fluorescent lighting
86 ± 8.6 UE/M2/S (400 ± 40 ft-c)
Continuous illumination
125 mLor 250 mL
50 mLor 100 mL
None
4 to 7 days
10,000 cells/mL
3
100 cpm continuous, or twice daily by hand
Algal stock culture medium without EDTA or
enriched surface water
Minimum of 5 and a control
Approximately 0.3 or 0.5
96 h
Growth (cell counts, chlorophyll
fluorescence, absorbance, biomass)
2 X 10s cells/mL in the controls; Variability of
controls should not exceed 20%
1 L (one sample for test initiation)
1 Surface water samples for toxicity tests are used undiluted.
H-13
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-9
Summary of Test Conditions and Test Acceptability Criteria for Ceriodaphnia dubia
Acute Toxicity Tests With Effluents and Receiving Waters
1. Test type:
2. Test duration:
3. Temperature:1
4. Light quality:
5. Light intensity:
6. Photoperiod:
7. Test chamber size:
8. Test solution volume:
9. Renewal of test solutions:
10. Age of test organisms:
11. No. organisms per test chamber:
12. No. replicate chambers per
concentration:
13. No. organisms per concentration:
14. Feeding regime:
15. Test chamber cleaning:
16. Test solution aeration:
Static non-renewal, static-renewal, or flow-
through
24, 48, or 96 h
200C±1°Cor250C±1°C
Ambient laboratory illumination
10-20 uE/m2/s (50-100 ft-c) (ambient
laboratory levels)
16 h light, 8 h darkness
30 mL (minimum)
15 mL (minimum)
Minimum, after 48 h
Less than 24-h old
Minimum, 5 for effluent and receiving water
tests
Minimum, 4 for effluent and receiving water
tests
Minimum, 20 for effluent and receiving water
tests
Feed YCT and Selenastrum while holding
prior to the test; newly-released young
should have food available a minimum of 2
h prior to use in a test; add 0.1 mL each of
YCT and Selenastrum 2 h prior to test
solution renewal at 48 h
Cleaning not required
None
1 Acute and chronic toxicity tests performed simultaneously to obtain acute/chronic ratios must use the same
temperature and water hardness.
H-14
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-9
Summary of Test Conditions and Test Acceptability Criteria for Ceriodaphnia dubia
Acute Toxicity Tests With Effluents and Receiving Waters (Continued)
17. Dilution water:
18. Test concentrations:
19. Dilution series:
20. Endpoint:
21. Sampling and sample holding
requirements:
22. Sample volume required:
23. Test acceptability criterion:
Moderately hard synthetic water prepared
using MILLIPORE MILLI-QR or equivalent
deionized water and reagent grade
chemicals or 20% DMW (see Section 7),
receiving water, or synthetic water modified
to reflect receiving water hardness.
Effluents: Minimum of five effluent
concentrations and a control
Receiving Waters: 100% receiving water
and a control
Effluents: > 0.5 dilution series
Receiving Waters: None, or > 0.5 dilution
series
Effluents: Mortality (LC50 or NOAEC)
Receiving Waters: Mortality (Significant
difference from control)
Effluents and Receiving Waters: Grab or
composite samples are used within 36 h of
completion of the sampling period.
1 L
90% or greater survival in controls
H-15
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-10
Summary of Test Conditions and Test Acceptability Criteria for Daphia pulex
and D. magna Acute Toxicity Tests With Effluents and Receiving Waters
1. Test type:
2. Test duration:
3. Temperature:1
4. Light quality:
5. Light intensity:
6. Photoperiod:
7. Test chamber size:
8. Test solution volume:
9. Renewal of test solutions:
10. Age of test organisms:
11. No. organisms per test chamber:
12. No. replicate chambers per
concentration:
13. No. organisms per concentration:
14. Feeding regime:
15. Test chamber cleaning:
16. Test solution aeration:
Static non-renewal, static-renewal, or flow-
through
24, 48, or 96 h
200C±10C or25°C±1°C
Ambient laboratory illumination
10-20 uE/m2/s (50-100 ft-c) (ambient
laboratory levels)
16 h light, 8 h darkness
30 mL (minimum)
25 mL (minimum)
Minimum, after 48 h
Less than 24-h old
Minimum, 5 for effluent and receiving water
tests
Minimum, 4 for effluent and receiving water
tests
Minimum, 20 for effluent and receiving water
tests
Feed YCT and Selenastrum while holding
prior to the test; newly-released young
should have food available a minimum of 2
h prior to use in a test; add 0.2 mL each of
YCT and Selenastrum 2 h prior to test
solution renewal at 48 h
Cleaning not required
None
1 Acute and chronic toxicity tests performed simultaneously to obtain acute/chronic ratios must use the same
temperature and water hardness.
H-16
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-10
Summary of Test Conditions and Test Acceptability Criteria for Daphia pulex
and D. magna Acute Toxicity Tests With Effluents and Receiving Waters (Continued)
17. Dilution water:
18. Test concentrations:
19. Dilution series:
20. Endpoint:
21. Sampling and sample holding
requirements:
22. Sample volume required:
23. Test acceptability criterion:
Moderately hard synthetic water prepared
using MILLIPORE MILLI-QR or equivalent
deionized water and reagent grade
chemicals or 20% DMW (see Section 7),
receiving water, or synthetic water modified
to reflect receiving water hardness.
Effluents: Minimum of five effluent
concentrations and a control
Receiving Waters: 100% receiving water
and a control
Effluents: > 0.5 dilution series
Receiving Waters: None, or > 0.5 dilution
series
Effluents: Mortality (LC50 or NOAEC)
Receiving Waters: Mortality (Significant
difference from control)
Effluents and Receiving Waters: Grab or
composite samples are used within 36 h of
completion of the sampling period.
1 L
90% or greater survival in controls
H-17
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-11
Summary of Test Conditions and Test Acceptability Criteria for Fathead Minnow
(Pinephales promotes) Acute Toxicity Tests With Effluents and Receiving Waters
1. Test type:
2. Test duration:
3. Temperature:1
4. Light quality:
5. Light intensity:
6. Photoperiod:
7. Test chamber size:
8. Test solution volume:
9. Renewal of test solutions:
10. Age of test organisms:
11. No. organisms per test chamber:
12. No. replicate chambers per
concentration:
13. No. organisms per concentration:
14. Feeding regime:
15. Test chamber cleaning:
16. Test solution aeration:
Static non-renewal, static-renewal, or flow-
through
24, 48, or 96 h
200C±1°Cor250C±1°C
Ambient laboratory illumination
10-20 uE/m2/s (50-100 ft-c) (ambient
laboratory levels)
16 h light, 8 h darkness
250 mL (minimum)
200 mL (minimum)
Minimum, after 48 h
1-14 days; 24-h range in age
Minimum, 10 for effluent and receiving water
tests
Minimum, 2 for effluent tests
Minimum, 4 for receiving water tests
Minimum, 20 for effluent tests
Minimum, 40 for receiving water tests
Artemia nauplii are made available while
holding prior to the test; add 0.2 mL Artemia
nauplii concentrate 2 h prior to test solution
renewal at 48 h
Cleaning not required
None, unless DO concentration falls below
4.0 mg/L; rate should not exceed 100
bubbles/min
1 Acute and chronic toxicity tests performed simultaneously to obtain acute/chronic ratios must use the same
temperature and water hardness.
H-18
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-11
Summary of Test Conditions and Test Acceptability Criteria for Fathead Minnow
(Pinephales promelas) Acute Toxicity Tests With Effluents and Receiving Waters
(Continued)
17. Dilution water:
18. Test concentrations:
19. Dilution series:
20. Endpoint:
21. Sampling and sample holding
requirements:
22. Sample volume required:
23. Test acceptability criterion:
Moderately hard synthetic water prepared
using MILLIPORE MILLI-QR or equivalent
deionized water and reagent grade
chemicals or 20% DMW (see Section 7),
receiving water, or synthetic water modified
to reflect receiving water hardness.
Effluents: Minimum of five effluent
concentrations and a control
Receiving Waters: 100% receiving water
and a control
Effluents: > 0.5 dilution series
Receiving Waters: None, or > 0.5 dilution
series
Effluents: Mortality (LC50 or NOAEC)
Receiving Waters: Mortality (Significant
difference from control)
Effluents and Receiving Waters: Grab or
composite samples are used within 36 h of
completion of the sampling period.
2 L for effluents and receiving waters
90% or greater survival in controls
H-19
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-12
Summary of Test Conditions and Test Acceptability Criteria for Mysid Shrimp
(Mysidopsis bahia) Acute Toxicity Tests With Effluents and Receiving Waters
1. Test type:
2. Test duration:
3. Temperature:1
4. Light quality:
5. Light intensity:
6. Photoperiod:
7. Test chamber size:
8. Test solution volume:
9. Renewal of test solutions:
10. Age of test organisms:
11. No. organisms per test chamber:
12. No. replicate chambers per
concentration:
13. No. organisms per concentration:
14. Feeding regime:
15. Test chamber cleaning:
16. Test solution aeration:
Static non-renewal, static-renewal, or flow-
through
24, 48, or 96 h
20°C± 1°C or25°C± 1°C
Ambient laboratory illumination
10-20 uE/m2/s (50-100 ft-c) (ambient
laboratory levels)
16 h light, 8 h darkness
250 mL (minimum)
200 mL (minimum)
Minimum, after 48 h
1 - 5 days; 24-h range in age
Minimum, 10 for effluent and receiving water
tests
Minimum, 2 for effluent tests
Minimum, 4 for receiving water tests
Minimum, 20 for effluent tests
Minimum, 40 for receiving water tests
Artemia nauplii are made available while
holding prior to the test; add 0.2 mL of
concentrated suspension of Artemia nauplii
< 24 h old, daily (approximately 100 nauplii
per mysid)
Cleaning not required
None, unless DO concentration falls below
4.0 mg/L; rate should not exceed 100
bubbles/min
1 Acute and chronic toxicity tests performed simultaneously to obtain acute/chronic ratios must use the same
temperature and water hardness.
H-20
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-12
Summary of Test Conditions and Test Acceptability Criteria for Mysid Shrimp
(Mysidopsis bahia) Acute Toxicity Tests With Effluents and Receiving Waters
(Continued)
17. Dilution water:
18. Test concentrations:
19. Dilution series:
20. Endpoint:
21. Sampling and sample holding
requirements:
22. Sample volume required:
23. Test acceptability criterion:
5-30 °/oo ± 10%; modified GP2, Forty
FathomsR, or equivalent, artificial seawater
prepared with MILLI-QR, or equivalent,
deionized water (see Section 7); or receiving
water
Effluents: Minimum of five effluent
concentrations and a control
Receiving Waters: 100% receiving water
and a control
Effluents: > 0.5 dilution series
Receiving Waters: None, or > 0.5 dilution
series
Effluents: Mortality (LC50 or NOAEC)
Receiving Waters: Mortality (Significant
difference from control)
Effluents and Receiving Waters: Grab or
composite samples are used within 36 h of
completion of the sampling period.
1 L for effluents
2 L for receiving water
90% or greater survival in controls
H-21
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-13
Summary of Test Conditions and Test Acceptability Criteria for Silverside
(Menidia beryllina, M. menidia, and M. peninsulae) Acute Toxicity Tests
With Effluents and Receiving Waters
1. Test type:
2. Test duration:
3. Temperature:1
4. Light quality:
5. Light intensity:
6. Photoperiod:
7. Test chamber size:
8. Test solution volume:
9. Renewal of test solutions:
10. Age of test organisms:
11. No. organisms per test chamber:
12. No. replicate chambers per
concentration:
13. No. organisms per concentration:
14. Feeding regime:
15. Test chamber cleaning:
16. Test solution aeration:
Static non-renewal, static-renewal, or flow-
through
24, 48, or 96 h
200C±1°Cor250C±1°C
Ambient laboratory illumination
10-20 uE/m2/s (50-100 ft-c) (ambient
laboratory levels)
16 h light, 8 h darkness
250 mL (minimum)
200 mL (minimum)
Minimum, after 48 h
9-14 days; 24-h range in age
Minimum, 10 for effluent and receiving water
tests
Minimum, 2 for effluent tests
Minimum, 4 for receiving water tests
Minimum, 20 for effluent tests
Minimum, 40 for receiving water tests
Artemia nauplii are made available while
holding prior to the test; add 0.2 mL Artemia
nauplii concentrate 2 h prior to test solution
renewal at 48 h
Cleaning not required
None, unless DO concentration falls below
4.0 mg/L; rate should not exceed 100
bubbles/min
1 Acute and chronic toxicity tests performed simultaneously to obtain acute/chronic ratios must use the same
temperature and water hardness.
H-22
-------
Appendix H
Recommended Effluent Toxicity Test Conditions
Table H-13
Summary of Test Conditions and Test Acceptability Criteria for Silverside
(Menidia beryllina, M. menidia, and M. peninsulae) Acute Toxicity Tests
With Effluents and Receiving Waters (Continued)
17. Dilution water:
18. Test concentrations:
19. Dilution series:
20. Endpoint:
21. Sampling and sample holding
requirements:
22. Sample volume required:
23. Test acceptability criterion:
Modified GP2, Forty Fathoms0, or
equivalent, artificial seawater prepared with
MILLI-QR, or equivalent, deionized water
(see Section 7); or receiving water:
1-32 °/oo ± 10% for M. beryllina;
15-32 °/oo + 10% for M. menidia and M.
peninsulae
Effluents: Minimum of five effluent
concentrations and a control
Receiving Waters: 100% receiving water
and a control
Effluents: > 0.5 dilution series
Receiving Waters: None, or > 0.5 dilution
series
Effluents: Mortality (LC50 or NOAEC)
Receiving Waters: Mortality (Significant
difference from control)
Effluents and Receiving Waters: Grab or
composite samples are used within 36 h of
completion of the sampling period.
1 L for effluents
2 L for receiving water
90% or greater survival in controls
H-23
-------
-------
APPENDIX I
SLUDGE INSPECTION CHECKLISTS
-------
-------
Appendix I
Sludge Inspection Checklists
PERMIT VERIFICATION
Yes No N/A 1.
Yes No N/A
Yes No N/A
Yes No N/A
Are 40 CFR Part 503 sludge use and disposal requirements
contained in a current NPDES permit, in a separate "sludge
only" NPDES permit, in a RCRA Subtitle C permit, or in a CAA
permit? [503.3 (a) (1) or (2)] (1)
Sludge use and disposal practice(s):
a. Land Application [503.10]
Bulk Sewage Sludge
[503.11(e)]
or
Bulk Material Derived From Sewage Sludge
[503.11(e)]
Sold or Given Away in a Bag or Other Container
[503.110)1
b. Surface Disposal
[503.20]
c.
d.
Sewage Sludge Incineration [503.40]
On or Off Site Storage [503.9(y)]
Date storage began ended
e.
(Maximum time allowed: 2 years from February 19, 1993)
Other (list)
Each sludge use or disposal practice is permitted?
[503.3(a) (1)] (1)
Notification is given to EPA/State of new or different sludge
disposal method? [Permit]
Number and location of disposal sites/activities are as described
in the permit or fact sheet or land application plan (40 CFR Part
501)? [Permit]
Comments:
1-1
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Appendix I Sludge Inspection Checklists
RECORDKEEPING AND REPORTING EVALUATION
Yes No N/A 1. Self-monitoring data are available for all regulated pollutants?
[503.17], [503.27], [503.43]
Yes No N/A 2. Pathogen and vector attraction reduction method description and
certification statement available? [503.17], [503.27]
Yes No N/A 3. Records are available for all use or disposal practices?
[503.17], [503.27], [503.47]
Yes No N/A 4. Accurate records of sludge volume or mass are maintained,
when appropriate? [503.25], [503.47]
Yes No N/A 5. Monitoring and analyses are performed more often than required
by permit? If so, results are reported in the permittee's self-
monitoring report? [Permit]
Yes No N/A 6. Unit operations records verify compliance with pathogen and
vector attraction reduction requirements, when appropriate?
[503.15], [503.25]
Yes No N/A 7. Self-monitoring is conducted at the frequency specified in the
permit, in 503.16 Table 1 (land application), or in 503.26 Table 1
(surface disposal)? [503.16], [503.26] or [503.46 Table 1
(incineration)] (Production dependent 0-289 mtpy: 1/yr., 290-
1499 mtpy: 1/qtr., 1500-14999 mtpy: 1/2 mo., 15000 mtpy and
greater, 1/mo.) mtpy-metric ton per year
Yes No N/A 8. Facility reports sludge monitoring data at the frequency specified
in the permit? (Only for Class I facilities, total design flow >1
mgd, or serving >10,000 people) [503.18], [503.28], [503.48]
Yes No N/A 9. Sludge records are maintained for at least 5 years? [503.17],
[503.27], [503.47]
Yes No N/A 10. Sludge data are reported on Discharge Monitoring Report (DMR)
or approved form? [Permit]
Yes No N/A 11. Sludge records are adequate to assess compliance with annual
and/or cumulative pollutant loading rates or other established
permit limits? [503.13(a) (2) (i)], [503.13(a) (4) (ii)]
Comments:
I-2
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Appendix I Sludge Inspection Checklists
SLUDGE SAMPLING AND ANALYSIS EVALUATION
Yes No N/A 1. Sludge samples are taken at locations specified in the permit?
[Permit]
Yes No N/A 2. Sludge sample locations are appropriate for obtaining
representative samples? [503.8(a)]
Yes No N/A 3. Sampling and analysis are conducted for parameters specified in
the permit or in 40 CFR Part 503? [Permit], [503.13], [503.23],
[503.46]
4. Sample collection procedures
Yes No N/A a. Adequate sample volumes are obtained?
Yes No N/A b. Proper preservation techniques are used?
Yes No N/A c. Containers conform to appropriate analytical method
specified in 40 CFR Part 503.8?
Yes No N/A d. Samples analyzed in the appropriate timeframes in
accordance with 40 CFR Part 503.8?
Yes No N/A 5. Are results reported on a dry weight basis? [503.13], [503.23],
[503.43]
(Dry weight concentration = Wet weight concentration/Decimal
fraction of solids)
e.g. A sludge containing 20 mg/l Cu and having 5% solids.
Dry weight Cu (mg/kg) = 20 mg/1 = 400 mg/kg
0.05
Yes No N/A 6. Sample is refrigerated subsequent to compositing?
Yes No N/A 7. Chain-of-custody procedures are employed?
Yes No N/A 8. Analytical methods used are approved methods of 40 CFR Part
503.8?
Comments:
I-3
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Appendix I Sludge Inspection Checklists
UNIT PROCESSES
General Sludge Processes
Yes No N/A 1. Sludge process control parameters maintained as appropriate?
Yes No N/A 2. Adequate equipment redundancy (e.g., back-up units)?
Yes No N/A 3. Adequate sludge storage capacity?
Yes No N/A 4. Contingency plan for sludge disposal practice?
Yes No N/A 5. Solids handling operation adequate to manage volume of
sludge?
Comments:
Drying Beds, Gravity Thickener, Centrifuge, and Dissolved Air Flotation
Yes No N/A 1. Is primary unstabilized sludge fed to the thickener, centrifuge or
drying bed?
If yes, list percentage of unstabilized sludge .
2. What is the average % solids of thd sludge before thickening,
drying or centrifuging? % after?
Yes No N/A 3. Is sludge mixed with other materials before or after thickening?
Yes No N/A 4. For sludge containing unstabilized solids, is the percent solids
greater than 90% prior to mixing with other materials?
Yes No N/A 5. For sludge containing no unstabilized solids, is the percent
solids greater than 75% prior to mixing with other materials?
Comments:
I-4
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Appendix
Sludge Inspection Checklists
UNIT PROCESSES (Continued)
Anaerobic Digestion
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
1.
2.
3.
4.
5.
6.
Sludge fed to digester(s) includes:
Primary Secondary Combined
Digester(s) operating mode:
high rate low rate
Digester(s) are operated at proper temperature [mesophilic: 95°F
(35°C) and thermophilic: 131°F (55°C)?
List operating mode mesophilic
thermophilic
Temperature monitoring location and frequency sufficient to
demonstrate compliance with Class B pathogen reduction
requirements for PSRP?
Average Temperature:
°C or °F
Solids Retention Time (SRT) or Mean Cell Residence time
(MCRT) calculated properly?*
SRT or MCRT sufficient to demonstrate compliance with Class B
pathogen reduction requirements for PSRP?
Average SRT or MCRT:
.days
*For batch operated digesters with no recycle:
SRT or MCRT = Mass of solids in digester, kg
Solids removed, kg/day
This formula can be used to estimate SRT or MCRT for all
digester systems. For calculating SRT or MCRT for other
system configurations, use the WEF Manual of Practice or other
references. Always write down the calculation used by the
facility no matter what the configuration is.
Comments:
I-5
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Appendix
Sludge Inspection Checklists
UNIT PROCESSES (Continued)
Aerobic Digestion
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Sludge fed to digester(s) includes:
Primary Secondary Combined
Digester(s) operating mode:
high rate low rate
Digester(s) are operated at proper temperature [cryophilic: <50°F
(<10°C), mesophilic: 50-108°F (10-42°C), and thermophilic:
>108°F (42°C)]?
List operating mode
mesophilic
cryophilic
thermophilic
Temperature monitoring location and frequency sufficient to
demonstrate compliance with Class B pathogen reduction
requirements for PSRP or with Class A pathogen reduction
requirements for PFRP (Thermophilic aerobic digestion only)?
Average Temperature:
°C or °F
Solids Retention Time (SRT) or Mean Cell Residence time
(MCRT) calculated properly?*
SRT or MCRT sufficient to demonstrate compliance with Class B
pathogen reduction requirements for PSRP or with Class A
pathogen reduction requirements for PFRP (Thermophilic
digestion only)?
Average SRT or MCRT:
_days
Aerobic conditions verified through dissolved oxygen monitoring?
*For batch operated digesters with no recycle:
SRT or MCRT = Mass of solids in digester, kg
Solids removed, kg/day
This formula can be used to estimate SRT or MCRT for all
digester systems. For calculating SRT or MCRT for other
systems configurations, use the WEF Manual of Practice or
other references. Always write down the calculation used by the
facility no matter what the configuration is.
Comments:
I-6
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Appendix I
Sludge Inspection Checklists
UNIT PROCESSES (Continued)
Composting
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Comments:
1. Type of composting performed:
In vessel Static piles Windrows
2. Type of sludge composted:
Primary Secondary Combined
3. Is the moisture content monitored?
4. Is compost mixed? Method
Frequency of turnings?
5. Is oxygen content monitored?
6. Is temperature monitored?
7. Are total and total volatile solids monitored?
8. Active phase.
Curing phase
days
.days
9. Is site runoff treated? Where?
10. Temperature monitoring location and frequency sufficient to
demonstrate compliance with Class B pathogen reduction
requirements for PSRP or with Class A pathogen reduction
requirements for PFRP?
11. Temperature and/or oxygen monitoring sufficient to determine
compliance with vector attraction reduction requirements?
I-7
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Appendix I Sludge Inspection Checklists
LAND APPLICATION OF SEWAGE SLUDGE
Yes No N/A 1. Sewage sludge or material derived from sewage sludge is land
applied to:
Agricultural Land Forest
Public Contract Site (park, etc.)
Reclamation Site Lawn or Home Garden
Yes No N/A 2. Do monitoring results show pollutant concentrations below
values shown in 40 CFR Part 503.13(b)(1) Table 1?
[503.13(a)(1)] (2)
Yes No N/A 3. Do monitoring results show pollutant concentrations below
values shown in 40 CFR Part 503.13(b)(3)? (3)
4. Classifications of Sewage Sludge with respect to Pathogens:
[503.30] (4)
Class A Class B Unknown
Yes No N/A 5. Are Class A Pathogen reductions requirements met? [503.15(a)]
(4)
6. Indicate which method is used to meet Class A requirements:
[503.32(a)]
Fecal conform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and Time/Temperature requirements.
[503.32(a)(3)]
Fecal Coliform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and pH requirements. [503.32(a)(4)]
Fecal Coliform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and enteric viruses or helminth ova
reduction requirements. [503.32(a)(5)]
Fecal Coliform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and enteric viruses or helminth ova density
requirements. [503.32(a)(6)]
Fecal Coliform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and Process to Further Reduce Pathogens
(PFRP). [503.32(a)(7)J and [503 Appendix B] (5)
Fecal Coliform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and equivalent PFRP. [503.32(a)(8)J and
[503 Appendix B] (5)
I-8
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Appendix I Sludge Inspection Checklists
LAND APPLICATION OF SEWAGE SLUDGE (Continued)
Yes No N/A 7. Are Class B Pathogen reduction requirements met? [503.32(b)]
(4)
8. Indicate which method(s) is used to meet Class B requirements:
Geometric mean of seven samples which Fecal Coliform
<2,000,000 MPN/g total solids or <2,000,000 Colony Forming
Units/g total solids. [503.32(b)(2)]
Treated by Process to Significantly Reduce Pathogens (PSRP).
[503.32(b)(3)] and [503 Appendix B] (5)
Treated by equivalent PSRP. [503.32(b)(4)] and [503 Appendix
B](5)
Yes No N/A 9. For Class B sludge which is land applied, are Site Restrictions
practiced? [503.32 (b)(5)] (4)
10. Indicate Site Restrictions practiced where applicable:
Food crops (above ground) are harvested >14 months after
application of sewage sludge? [503.32(b)(5)(i)]
Food Crops (below ground) are harvested >20 months after
application of sewage sludge when sludge stays on land for >4
months prior to incorporation into soil? [503.32(b)(5)(ii)]
Food Crops (below ground) are harvested >38 months after
application of sewage sludge when sludge stays on land for <4
months prior to incorporation into soil? [503.32(b)(5)(iii)
Food Crops, feed crops, and fiber crops are harvested >30 days
after application of sewage sludge? [503.32(b)(5)(iv)]
Animal grazing allowed on land only >30 days after application
of sewage sludge? [503.32(b)(5)(v)]
Turf grown on land where sewage sludge was applied placed on
high public expose land or lawn is harvested >1 year after
application of sewage sludge? [503.32(b)(5)(vi)]
Public access is restricted to land with a potential for high public
exposure for 1 year? [503.32(b)(5)(vii)]
Public access is restricted to land with a potential for low public
exposure for 30 days? [503.32(b)(5)(viii)]
I-9
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Appendix I Sludge Inspection Checklists
LAND APPLICATION OF SEWAGE SLUDGE (Continued)
Yes No N/A 11. Is a Vector Attraction Reduction method practiced? [503.15(c)]
(6)
12. Indicate Vector Attraction Reduction method:
[503.33(b)]
38% Volatile Solids Reduction. [503.33(b)(1)] (7)
40 day test - Volatile Solids reduced <17%.
[503.33(b)(2)J (Anaerobic Digestion Only)
30 day test - Volatile Solids reduced <15%.
[503.33(b)(3)] (Aerobic Digestion Only)
Specific Oxygen Uptake Rate (SOUR) <=1.5 mg/hr/gm TS @
20°C. [503.33(b)(4J]
Aerobic Process for >14 days @ >40°C with average sludge
temperatures >45°C. [503.33(b)(5)]
pH >12 for 2 hours and pH >11.5 for 22 hours [503.33(b)(6)]
Sludge (with no unstabilized solids) contains >75% Total Solids
prior to mixing with other materials. [503.33(b)(7)]
Sludge (contains unstabilized solids) contains >90% Total Solids
prior to mixing with other materials. [503.33(b)(8)]
Subsurface Injection. [503.33(b)(9)j
Soil Incorporation. [503.33(b)(10)]
Yes No N/A 13. Are general requirements (503.12) and management practices
(503.14) applied for sludge not meeting Table 3 pollutant
concentrations, Class pathogen reduction requirements, and
vector attraction reduction methods? [503.10], [503.12], [503.14]
14. Indicate management practices where applicable:
No threatened or endangered species present or critical habitat
affected at the location(s) where bulk sludge is applied.
Bulk sludge not applied to frozen or snow covered ground.
Bulk sludge applied >10 meters from waters of the U.S.
1-10
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Appendix I Sludge Inspection Checklists
LAND APPLICATION OF SEWAGE SLUDGE (Continued)
Bulk sludge applied at a rate equal to or less than agronomic
rate.
Label affixed on bag or information sheet provided to user of
sold and given away sludge indicating name of sludge preparer,
application instructions, and maximum annual whole sludge
application rate.
15. Indicate general requirements practiced where applicable:
Sludge is not applied to a site where the cumulative pollutant
loading or annual application rate has been reached.
Notification given to the sludge applier regarding total nitrogen
content of the sludge.
Sufficient information required to comply with 40 CFR Part 503 is
given to preparers/appliers/land owners.
Written notification given to permitting authority (including States)
regarding the location of land application sites, appropriate
NPDES permit numbers.
Yes No N/A 16. Description of how management practices are met for each land
application site available?
Comments:
1-11
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Appendix I Sludge Inspection Checklists
LAND APPLICATION OF SEWAGE SLUDGE (Continued)
FOOTNOTES
(1) Permits are not required -503 is self-implementing. 503 does not require industrial
sludges or grit and screenings.
(2) 503.13(b)(1), Table 1 values must be met to land apply sludge:
Table 1 (mg/kg)
Arsenic • 75 Mercury 57
Cadmium 85 Molybdenum 75
Chromium 3000 Nickel 420
Copper 4300 Selenium 100
Lead 840 Zinc 7500
(3) 503.13(b)(3), Table 3 must be met for any sludge applied to a lawn or home garden.
For bulk sludge, Table 3 must be met or the sludge is subject to cumulative loading
limits in 503.13(b)(2). For sewage sludge sold and given away in a bag or other
container, Table 3 must also be met or the sludge is subject to annual pollutant
loadings in 503.13(b)(4). This also signals that additional recordkeeping requirements
of 503.12 and 503.17 apply.
Table 1 (mg/kg)
Arsenic 41 Mercury 17
Cadmium 39 Molybdenum 18
Chromium 1200 Nickel 420
Copper 1500 Selenium 36
Lead 300 Zinc 2800
(4) Class A requirements must be met when bulk sludge is land applied to a lawn or home
garden, or when sewage sludge is sold or given away in a bag or other container.
Also, Class A requirements or Class B requirements combined with appropriate site
restrictions must be met for when bulk or bulk material derived from sludge is applied
to agricultural land, reclamation site, forest, or public contact site.
(5) Process to Significantly Reduce Pathogens (PSRP)—Includes Aerobic Digestion, Air
Drying, Anaerobic Digestion, Composting, and Lime Stabilization. Process to Further
Reduce Pathogens (PFRP)—Includes Composting, Heat Drying, Heat Treatment,
Thermophilic Aerobic Digestion, Beta Ray Irradiation, Gamma Ray Irradiation, and
Pasteurization. Each process has required operating conditions to demonstrate
compliance. See 503 Appendix B and Unit Process Checklists.
1-12
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Appendix I Sludge Inspection Checklists
LAND APPLICATION OF SEWAGE SLUDGE (Continued)
FOOTNOTES
(6) One of the methods 503.33(b)(1)-(10) must be used when land applying bulk sewage
sludge to agricultural land, forest, a public contact site, or a reclamation site. One of
the methods 503.33(b)(1)-(8) must be met when land applying bulk sludge to a lawn or
home garden, or when sewage sludge or derived material is sold or given away in a
bag or other container.
(7) Volatile solids reduction through the sludge treatment train only is calculated using the
following general formula:
% VS Reduction = (Mass of solids in, kg X Mass of solids out, kg) x 100
Mass of solids in, kg
Variations of this formula are presented in the document Environmental Regulations
and Technology-Control of Pathogens and Vector Attraction in Sewage Sludge, EPA-
625/R-92/013. See for specific calculations.
1-13
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Appendix I
Sludge Inspection Checklists
SURFACE DISPOSAL
Yes No N/A 1.
2.
Yes No N/A
Yes No N/A
3.
4.
Yes No N/A 5.
6.
Does each Surface Disposal Unit (SOU) have a liner and
leachate collection system?
Smallest distance from active SOU boundary to property
boundary is ft.
For an active SOU (property boundary is greater that 150 meters
from SOU) and without a liner or leachate collection system, do
monitoring results show pollutant concentrations below values
shown in 40 CFR Part 503.23(a)(1) Table 1? [503.23(a)(1)] (1)
For an active SOU without a liner and leachate collection system
(property boundary is less than 150 meters from SOU), do
monitoring results show pollutant concentrations below values
shown in 40 CFR Part 503.23(a)(2) Table 2? [503.23(a)(1)] (2)
Are management practices employed? [503.24]
List management practices where applicable:
No threatened or endangered species present or critical habitat
affected at the location where bulk sludge is surface disposed.
Surface disposal unit shall not restrict flow of base flood.
If in seismic impact zone, design will withstand recorded
horizontal ground acceleration.
Located > 60 meters from any fault displaced in Holocene time.
Not located in unstable area or wetlands.
Runoff collection and treatment with 25-year 24-hour storm
runoff event storage capacity.
Leachate collection system operated and maintained for 3 years
after closure of the surface disposal unit.
Leachate treated and disposed of in accordance with applicable
requirements, i.e., NPDES permit?
Is methane contained under covered units at a concentration
less than 25% of the LEL for methane?
1-14
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Appendix I Sludge Inspection Checklists
SURFACE DISPOSAL (Continued)
Is methane contained under a final cover placed on a closed unit
maintained at a concentration less than 25% of the LEL for
methane for three years after closure?
Is methane concentration at the property line maintained at a
concentration less that the LEL for methane for three years after
closure of the unit?
No feed or food crops grown on active unit. (3)
No animal grazing allowed on active unit. (3)
Public access restricted for the period of time while a unit is
active and for three years after last active unit in a site closes.
Sludge placed in an active unit does not contaminate
groundwater aquifers. (4)
Yes No N/A 7. Is a Vector Attraction Reduction method practiced? [503.25(b)]
(5)
8. Indicate Vector Attraction Reduction method: [503.33(b)]
38% Volatile Solids reduction. [503.33(b)(1)]
40 day test - Volatile solids reduced <17%. [503.33(b)(2)J
(Anaerobic Digestion Only)
30 day test - Volatile Solids reduced <15%. [503.33(b)(3)]
(Aerobic Digestion Only)
Specific Oxygen Uptake Rate (SOUR) <1.5 mg/hr/gm TS @
20°C. [503.33(b)(4)]
Aerobic Process for >14 days @ >40° C with average sludge
temperature >45° C. [503.33(b)(5)]
pH >12 for 2 hours and pH >11.5 for 22 hours [503.33(b)(6)]
Sludge (with no unstabilized solids) contains >75% Total Solids
prior to mixing with other materials. [503.33(b)(7)]
Sludge (contains unstabilized solids) contains >90% Total Solids
prior to mixing with other materials. [503.33(b)(8)]
1-15
-------
Appendix I Sludge Inspection Checklists
SURFACE DISPOSAL (Continued)
Subsurface Injection. [503.33(b)(9)]
Soil Incorporation. [503.33(b)(10)J
Sludge covered with soil or other material at the end of the day.
[503.33(b)(11)]
9. Classification of Sewage Sludge with respect to Pathogens:
[503.30]
Class A Class B Unknown
Yes No N/A 10. Are Class A Pathogen reduction requirements met? [503.25(a)]
(6)
11. Indicate which method is used to meet Class A requirements:
[503.32(a)]
Fecal Coliform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and Time/Temperature requirements.
[503.32(a)(3>]
Fecal Coliform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and pH requirements. [503.32(a)(4)]
Fecal Coliform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and enteric viruses or helminth ova
reduction requirements. [503.32(a)(5)]
Fecal Coliform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and enteric viruses or helminth ova density
requirements. [503.32(a)(6)J
Fecal Coliform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and Process to Further Reduce Pathogens
(PFRP). [503.32(a)(7)] and [503 Appendix B] (7)
Fecal Coliform <1000 MPN/g total solids, or Salmonella <3
MPN/4 g total solids, and equivalent PFRP. [503.32(a)(7)] and
[503 Appendix B] (7)
Yes No N/A 12. Are Class B pathogen reduction requirements met? [503.32(b)]
(6)
1-16
-------
Appendix I Sludge Inspection Checklists
SURFACE DISPOSAL (Continued)
13. Indicate which method(s) is used to meet Class B requirements:
Geometric mean of seven samples with Fecal Coliform
<2,000,000 MPN/g total solids or <2,000,000 Colony Forming
Units/g total solids. [503.32(b)(2)J
Treated by Process to Significantly Reduce Pathogens.
[503.32(b)(3)] and [503 Appendix B] (7)
Treated by equivalent Process to Significantly Reduce
Pathogens. [503.32(b)(4)] and [503 Appendix B] (7)
Yes No N/A 14. Have any SDUs been closed?
Yes No N/A 15. Has facility submitted closure and post closure plan for any
active SOU 180 days prior to closing? [503.22(c)]
Comments:
1-17
-------
Appendix I Sludge Inspection Checklists
SURFACE DISPOSAL
FOOTNOTES
(1) Table 1 of 503.23(a)(1) must be met for all sludge placed in an active surface disposal
unit with a distance of greater than 150 meters from the boundary of the surface
disposal unit to the property line. Site specific limits can also be set by the permitting
authority in accordance with 503.23(b).
Table 1 (dry weight basis)
Pollutant Concentration (mg/kg)
Arsenic 73
Chromium 600
Nickel 420
(2) Table 2 of 503.23(a)(2) must be met for all sludge placed in an active surface disposal
unit with a distance of less than 150 meters from the boundary of the surface disposal
unit to the property line. Site specific limits can also be set by the permitting authority
in accordance with 503.23(b).
Table 2 (dry weight basis)
Unit boundary to property line Pollutant Concentration (mg/kg)
Distance (meters) Arsenic Chromium Nickel
0 to less than 25 ' 30 200 210
25 to less than 50 34 220 240
50 to less than 75 39 260 270
. 75 to less than 100 46 300 320
100 to less than 125 53 360 390
125 to less than 150 62 450 420
(3) Unless specific approval from the permitting authority has been obtained by the facility.
(4) Facility must have results of groundwater monitoring study developed by a qualified
groundwater scientist or a certification from a qualified groundwater scientist to
demonstrate no contamination.
(5) Facility must meet vector attraction reduction requirements of 503.33(b) to surface
dispose sludge.
1-18
-------
Appendix I Sludge Inspection Checklists
SURFACE DISPOSAL
FOOTNOTES (Continued)
(6) Facility must meet Class A pathogen reduction requirements of 503.32(a) or Class B
503.32(b)(2) through (b)(4) unless vector attraction reduction method 503.33(b)(11),
covering sludge at the end of the day, is used.
(7) Process to Significantly Reduce Pathogens (PSRP) - Includes Aerobic Digestion, Air
Drying, Anaerobic Digestion, Composting, and Lime Stabilization. Process to Further
Reduce Pathogens (PFRP) - Includes Composting, Heat Drying, Heat Treatment,
Thermophilic Aerobic Digestion, Beta Ray Irradiation, Gamma Ray Irradiation, and
Pasteurization. Each process has required operating conditions to demonstrate
compliance. See 503 Appendix B and Unit Process Checklist.
1-19
-------
Appendix I Sludge Inspection Checklists
SEWAGE SLUDGE INCINERATION
Yes No N/A 1. Does the incinerator meet the definition of a sewage sludge
incinerator?
Yes No N/A 2. Do sewage sludge monitoring results show pollutant
concentrations below permit limits?
Yes No N/A 3. Does THC monitoring show concentrations below 100 ppm
(monthly average)?
Yes No N/A 4. Are there instruments installed that continuously measure and
record THC (or alternatively CO), oxygen concentration, moisture
content, and combustion temperatures?
Yes No N/A 5. Is the THC instrument calibrated as required by 503.45 (once
every 24-hour period using propane) or the permit?
Yes No N/A 6. Are the other instruments calibrated as required by the permit?
Yes No N/A 7. Are the instruments operated and maintained as specified by the
permit?
8. How many times was the incinerator operated at above
the maximum combustion temperature specified in the permit?
For how long was the incinerator in operation above the
maximum combustion temperature?
9. How many times was the incinerator operated outside the range
of the air pollution control devices operating parameters
specified in the permit?
For how long was the incinerator in operation outside the
ranges?
Yes No N/A 10. Are the following records maintained:
Yes No N/A Concentration of lead, arsenic, cadmium, chromium, and nickel
in the sewage sludge fed to the sewage sludge incinerator.
Yes No N/A THC concentrations in the exit gas.
Yes No N/A Information that indicates NESHAP for beryllium in Subpart C of
40 CFR Part 61 are met.
I-20
-------
Appendix I Sludge Inspection Checklists
SEWAGE SLUDGE INCINERATION (Continued)
Yes No N/A Information that indicates NESHAP for mercury in Subpart E of
40 CFR Part 61 are met.
Yes No N/A Combustion temperatures, including maximum combustion
temperature.
Yes No N/A Values for air pollution control device operating parameters
Yes No N/A Oxygen concentration.
Yes No N/A Information used to measure moisture content in the exit gas.
Yes No N/A Sewage sludge feed rate.
Yes No N/A Stack height of incinerator.
Yes No N/A Dispersion factor for the site.
Yes No N/A Control efficiency for lead, arsenic, cadmium, chromium, and
nickel.
Yes No N/A Risk specific concentration for chromium (if applicable).
Yes No N/A Calibration and maintenance log for the instruments used to
measure THC (or CO), oxygen concentration, moisture content,
and combustion temperatures.
Yes No N/A Are these records maintained for 5 years?
Yes No N/A 11. Have all instances of noncompliance been reported as specified
by the permit?
Comments:
1-21
-------
APPENDIX J
APPROVED METHODS FOR THE ANALYSIS OF
SEWAGE SLUDGE (40 CFR 503)
-------
Appendix J
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Appendix J
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Appendix J
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Appendix J
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-------
-------
APPENDIX K
EPA INDUSTRIAL GENERAL PERMIT
CHECKLIST
STORM WATER POLLUTION PREVENTION
PLAN ANALYSIS
-------
Appendix K
EPA's Industrial General Permit Checklist
Storm Water Pollution Prevention Plan Analysis
Pollution Prevention Team
D Identify specific individuals
D Outline their responsibilities
2. Description of potential pollutant sources, including:
D Site map indicating:
D Drainage areas
D Drainage patterns/outfalls
D Structural and non-structural controls
D Surface waters
D Significant materials exposed to precipitation
D The location of leaks or spills that have occurred in the last 3 years
D Location of industrial activities exposed to precipitation including:
D Fueling stations
D Vehicle/equipment maintenance or cleaning areas
D Loading/unloading areas
D Waste treatment, storage, or disposal areas
D Liquid storage tanks
D Processing areas
D Storage areas
D A list of pollutants likely to be present in the discharges
D Description of significant materials handled, treated, stored, or disposed of such that
exposure to storm water occurred in the last 3 years
D Description of the method and location of storage or disposal
D Description of all material management practices
D Description and location of existing structural and non-structural controls
D List of significant spills and leaks that occurred in the 3 years prior to the effective
date of the permit
D Summary of existing storm water sampling data
D Description of areas with a high potential for significant soil erosion
D A narrative summarizing potential pollutant sources
K-1
-------
Appendix K EPA's Industrial General Permit Checklist
Storm Water Pollution Prevention Plan Analysis
3. A description of appropriate measures and controls, including:
D Good housekeeping procedures
D Preventive maintenance procedures
D Spill prevention and response procedures
D Inspection procedures
D Employee training program
D Recordkeeping and internal reporting procedures
D Non-storm water discharge certification or failure to certify non-storm water
discharge certification
D Identify authorized non-storm water discharges and appropriate controls
D Erosion and sediment controls for areas with a high erosion potential
D A narrative consideration of traditional storm water management practices
D Plans for implementation and maintenance of traditional measures found to be
reasonable and appropriate
4. D Annual site compliance evaluation reports (prepared after the inspection is
performed) including:
D A summary of the scope of the inspection
D Personnel making the inspection
D Major observations
D Actions taken to revise the Pollution Prevention Plan
D Certification of compliance or a list of incidents of non-compliance
5. D If discharging to a large or medium municipal separate storm sewer, compliance
with applicable requirements in the municipal storm water management program
6. D Consistency of the storm water pollution prevention plan with other plans
7. Additional requirements for facilities subject to Emergency Planning and Community
Right to Know Act (EPCRA) Section 313 requirements
D A description of the measures used in areas where section 313 water priority
chemicals are stored, processed, or otherwise handled to:
- Minimize the potential contact or storm water run-on with the chemicals
- Prevent exposure of the chemicals to storm water and wind
D -A discussion of the measures taken to minimize the discharge of Section 313 water
priority chemicals from the following areas:
D Liquid storage areas
D Non-liquid storage areas
D Truck and railcar loading areas
D Transfer, processing, or handling areas
D Other areas
K-2
-------
Appendix K EPA's Industrial General Permit Checklist
Storm Water Pollution Prevention Plan Analysis
Prevention Plan
D Preventive maintenance and housekeeping
D Facility security
D Training
D Professional Engineer (PE) certification every 3 years
8. D Assurance that any salt storage piles present onsite are covered or enclosed
K-3
-------
APPENDIX L
INDUSTRIAL SOURCE CONTROL BMP
QUESTIONS
-------
Appendix L Industrial Source Control BMP Questions
Industrial Source Control BMP Questions
FUELING
1: Has spill and overfill prevention equipment been installed?
2: Are vehicle fuel tanks often "topped off"?
3: Have steps been taken to protect fueling areas from rain?
4: Is runon to the fueling area minimized?
5: Are oil/water separators or oil and grease traps installed in storm drains in the fueling
area?
6: Is the fueling area cleaned by hosing or washing?
7: Do you control petroleum spills?
8: Are employees aware of ways to reduce contamination of storm water at fueling stations?
9: Where does the water drain from the fueling area?
SUMMARY OF FUELING STATION BMPs
Consider installing spill and overflow protection.
Discourage topping off of fuel tanks.
Reduce exposure of the fuel area to storm water.
Use dry cleanup methods for the fuel area.
Use proper petroleum spill control.
Encourage employee participation.
MAINTAINING VEHICLES AND EQUIPMENT
1: Are parts cleaned at the facility?
2: Has the facility looked into using nontoxic or less toxic cleaners or solvents?
3: Are work areas and spills washed or hosed down with water?
4: Are spills or materials washed or poured down the drain?
5: Are oil filters completely drained before recycling or disposal?
6: Are incoming vehicles and equipment checked for leaking oil and fluids?
7: Are wrecked vehicles or damaged equipment stored onsite?
8: Does the facility recycle any of the automotive fluids or parts?
9: Can the facility reduce the number of different solvents used?
10: Are wastes separated?
11: Does the facility use recycled products?
L-1
-------
Appendix L Industrial Source Control BMP Questions
SUMMARY OF VEHICLE MAINTENANCE AND REPAIR BMPs
Check for leaking oil and fluids.
Use nontoxic or low-toxicity materials.
Drain oil filters before disposal or recycling.
Do not pour liquid waste down drains.
Recycle engine fluids and batteries.
Segregate and label wastes.
Buy recycled products.
PAINTING VEHICLES AND EQUIPMENT
1: Is care taken to prevent paint wastes from contaminating storm water runoff?
2: Are wastes from sanding contained?
3: Are parts inspected before painting?
4: Is the facility using painting equipment that creates little waste?
5: Are employees trained to use spray equipment correctly?
6: Does the facility recycle paint, paint thinner, or solvents?
7: Are wastes separated?
8: Can the facility reduce the number of solvents used?
9: Does the facility use recycled products?
SUMMARY OF PAINTING OPERATION BMPs
Inspect parts prior to painting.
Contain sanding wastes.
Prevent paint waste from contacting storm water.
Use proper interim storage of waste paint, solvents, etc.
Evaluate efficiency of equipment.
Recycle paint, paint thinner, and solvents.
Segregate wastes.
Buy recycled products.
WASHING VEHICLES AND EQUIPMENT
1: Has the facility considered using phosphate-free biodegradable detergents?
2: Are vehicles, equipment, or parts washed over the open ground?
SUMMARY OF VEHICLE AND EQUIPMENT WASHING BMPs
Consider use of phosphate-free detergent.
Use designated cleaning areas.
Consider recycling wash water.
L-2
-------
Appendix L Industrial Source Control BMP Questions
LOADING AND UNLOADING MATERIALS
1: Are tank trucks and material delivery vehicles located where spills or leaks can be
contained?
2: Is loading/unloading equipment checked regularly for leaks?
3: Are loading/unloading docks or areas covered to prevent exposure to rainfall?
4: Are loading/unloading areas designed to prevent storm water runon?
5: Is piping system routinely checked for leaks?
SUMMARY OF LOADING/UNLOADING OPERATIONS BMPs
Contain leaks during transfer.
Check equipment regularly for leaks.
Limit exposure of material to rainfall.
Prevent storm water runon.
LIQUID STORAGE IN ABOVE-GROUND TANKS
1: Do storage tanks contain liquid hazardous materials, hazardous wastes, or oil?
2: Are operators trained in correct operating procedures and safety activities?
3: Does the facility have safeguards against accidental discharge?
4: Are tank systems inspected, and is tank integrity tested regularly?
5: Are tanks bermed or surrounded by a secondary containment system?
SUMMARY OF BMPs FOR LIQUID STORAGE IN ABOVE-GROUND TANKS
Comply with applicable State and Federal laws.
Properly train employees.
Install safeguards against accidental release.
Routinely inspect tanks and equipment.
Consider installing secondary containment.
INDUSTRIAL WASTE MANAGEMENT AND OUTSIDE MANUFACTURING
1: Has the facility looked for ways to reduce waste at the facility?
2: Has the facility considered waste reduction BMPs?
3: Are industrial waste management and outside manufacturing areas checked often for
spills and leaks?
4: Are industrial waste management areas or manufacturing activities covered, enclosed, or
bermed?
5: Are vehicles used to transport wastes to the land disposal or treatment site equipped with
anti-spill equipment?
6: Does the facility use loading systems that minimize spills and fugitive losses such as dust
or mists?
7: Are sediments .or wastes prevented from being tracked offsite?
8: Is storm water runoff minimized from the land disposal site?
L-3
-------
Appendix L Industrial Source Control BMP Questions
SUMMARY OF INDUSTRIAL WASTE MANAGEMENT AND OUTSIDE MANUFACTURING
BMPs
• Conduct a waste reduction assessment.
• Institute industrial waste source reduction and recycling BMPs.
• Prevent runoff and runon from contacting the waste management area.
• Minimize runoff from land application sites.
OUTSIDE STORAGE OF RAW MATERIALS. BY-PRODUCTS. OR FINISHED PRODUCTS
1: Are materials protected from rainfall, runon, and runoff?
SUMMARY OF BMPs FOR OUTSIDE STORAGE OF RAW MATERIALS,
BY-PRODUCTS, OR FINISHED PRODUCTS
Cover or enclose materials.
SALT STORAGE
1: Are salt piles protected from rain?
2: Is storm water runon prevented from contacting storage piles and loading and unloading
areas?
SUMMARY OF SALT STORAGE FACILITIES BMPs
Put salt under a roof.
Use temporary covers.
Enclose or berm transfer areas.
L-4
-------
APPENDIX M
EPA BASELINE CONSTRUCTION GENERAL
PERMIT REQUIREMENTS PRE-CONSTRUCTION
CHECKLIST
-------
Appendix M
EPA Baseline Construction General Permit
Requirements Pre-Construction Checklist
EPA BASELINE
2.
3.
4.
5.
6.
7.
n
n
n
n
n
n
n
A site description, including:
D The nature of the activity
Intended sequence of major construction activities
The total area of the site
The area of the site that is expected to undergo excavation
The runoff coefficient of the site after construction is complete
Existing soil or storm water data
A site map with:
D Drainage patterns
Approximate slopes after major grading
Area of soil disturbance
Indication of areas that will not be disturbed
Location of major structural and non-structural controls
Areas where stabilization practices are expected to occur
Surface waters
Storm water discharge locations
D The name of the receiving water(s).
A description of controls:
2.1 Erosion and sediment controls, including:
O Stabilization practices for all areas disturbed by construction
D Structural practices for all drainage/discharge locations
2.2 Erosion and sediment controls, including:
D Measures used to control pollutants occurring in storm water discharges after construction
activities are complete
D Velocity dissipation devices to provide nonerosive flow conditions from the discharge point along
the length of any outfall channel
2.3 Other controls including:
O Waste disposal practices that prevent discharge of solid materials to waters of the United States
D Measures to minimize offsite tracking of sediments by construction vehicles
n Measures to ensure compliance with State or local waste disposal, sanitary sewer, or septic
system regulations
2.4 Description of the timing during the construction when measures will be
implemented.
Are State or local requirements incorporated into the plans?
Are maintenance procedures for control measures identified in the plan?
Identification of allowable non-storm water discharges and pollution prevention measures.
Contractor certification.
Plan certification.
M-1
-------
Appendix M EPA Baseline Construction General Permit
Requirements Pre-Construction Checklist
GENERAL PEEWIT CHECKLIST
Stblrjrt Water Pollution
Construction/Implementation Checklist
1 . Maintains records of construction activities, including:
D Dates when major grading activities occur
D Dates when construction activities temporarily cease on a portion of the site
O Dates when construction activities permanently cease on a portion of the site
D Dates when stabilization measures are initiated on the site.
2. Prepare inspection reports summarizing:
D Name of inspector
D Qualifications of inspector
D Measures/areas inspected
D Observed conditions
D Changes necessary to the SWPPP.
3. Report releases of reportable quantities of oil or hazardous materials (if ihey occur):
D Notify National Response Center 800/424-8802
D Notify permitting authority in writing within 14 days
O Modify the Pollution Prevention Plan to include:
- the date of release
- circumstances leading to the release
- steps taken to prevent recurrence of the release.
4. Modify Pollution Prevention Plan as necessary to:
D Comply with minimum permit requirements when notified by EPA that the plan does not comply
D Address a change in design, construction operation or maintenance that has an effect on the potential
for discharge of pollutants
D Prevent recurrence of reportable quantity releases of a hazardous material or oil.
EPA BASELINE CONSTRUCTION GENERAL PERMIT,
Storm Water Pollution Prevention Plan
'f/ffttr %
* "' " "'" " ~ ~ ~ "" ' t \7 ^
' '' ^ ^J
1. All soil disturbing activities are complete.
2. Temporary erosion and sediment control measures have been removed or will be removed at an
appropriate time.
3. All areas of the construction site not otherwise covered by a permanent pavement or structure have been
stabilized with a uniform perennial vegetative cover with a density of 70% or equivalent.
M-2
-------
Appendix M
EPA Baseline Construction General Permit
Requirements Pre-Construction Checklist
POLLUTION PREVENTION PLAN FOR STORM WATER DISCHARGE ASSOCIATED WITH
CONSTRUCTION ACTIVITIES
EROSION AND SEDIMENT CONTROL SELECTION CHECKLIST
INSTRUCTIONS: THIS CHECKLIST LISTS THE MINIMUM SEDIMENT EROSION CONTROL REQUIREMENTS UNDER THE
USEPA GENERAL PERMIT. CHECK [/] EACH ITEM AND FILL IN THE BLANKS BELOW TO EVALUATE COMPLIANCE FOR
EACH DRAINAGE AREA AND LOCATION. NOTE: THIS CHECKLIST WAS PREPARED FOR THE USEPA GENERAL
PERMIT. REQUIREMENTS FOR STATE GENERAL PERMITS MAY VARY.
D
Stabilization Practices
Stabilization will be initiated on all disturbed areas where construction activity will not occur for a
period of more than 21 calendar days by the 14th day after construction activity has permanently or
temporarily ceased.
D
D
D
Stabilization measures to be used include:
Temporary Seeding fj Sod Stabilization
Permanent Seeding fj Geotextiles
Mulching U Other
Structural Practices
Flows from upstream areas will be diverted from exposed soils. Measures to be used include:
D Earth Dike 'D Pipe Slope Drain
D Drainage Swale CD Other
D Interceptor Dike and Swale
Drainage locations serving less than 10 disturbed
acres
n Sediment controls will be installed.
Sediment controls include:
D Sediment Basin
D Sediment Trap
D Silt Fence or equivalent controls
along all sideslope and downslope
boundaries
Drainage locations serving 10 or more disturbed
acres
D A Sediment Basin will be installed.
d A Sediment Basin is not attainable on the
site; therefore, the following sediment
controls will be installed:
Sediment Trap
Silt Fence or equivalent controls
along the sideslope and
downslope boundaries
X
3,600
Sediment Basin Runoff Storage Calculation
acres area draining to the sediment basin
cubic feet of storage/acre
cubic feet of storage required for the basin.
M-3
-------
APPENDIX N
CONSTRUCTION SOURCE CONTROL BMP
QUESTIONS
-------
Appendix N Construction Source Control BMP Questions
Construction Source Control BMP Questions
SOIL EROSION AND SEDIMENT CONTROL PRACTICES
MINIMIZE THE AMOUNT OF DISTURBED SOIL
1: Does the site plan require a significant amount of grade changes?
2: Are there portions of the site that do not have to be cleared for construction to proceed?
3: Can construction be performed in stages, so that the entire site does not have to be
cleared at one time?
4: Are there portions of the site that will be disturbed then left alone for long periods of
time?
5: Does the facility stabilize all disturbed areas after construction is complete?
6: Does snow prevent the facility from seeding an area?
7: Is there enough rainfall to allow vegetation to grow?
PREVENT RUNON FROM FLOWING ACROSS DISTURBED AREAS
1: Does runoff from the undisturbed uphill areas flow onto the construction site?
2: Will runoff flow down a steeply sloped, disturbed area on the site?
3: Is there a swale or stream that runs through the construction site?
4: Does construction traffic have to cross drainage swales or streams?
SLOW DOWN THE RUNOFF TRAVELING ACROSS THE SITE
1: Is the site gently sloped?
2: Is the site stabilized with vegetation?
3: Does runoff concentrate into drainage swales on the site?
REMOVE SEDIMENT FROM ONSITE RUNOFF BEFORE IT LEAVES THE SITE
1: Does the construction disturb an area 10 acres or larger that drains to a common
location?
2: Is a sediment basin attainable on the site?
3: Does runoff leave the disturbed area as overland flow?
4: Is the flow concentrated in channels as it leaves the disturbed areas?
5: Are structural controls located along the entire downhill perimeter of all disturbed areas?
6: Is there a piped storm drain system with inlets in a disturbed area?
N-1
-------
Appendix N Construction Source Control BMP Questions
MEET OR EXCEED LOCAL/STATE REQUIREMENTS FOR EROSION AND SEDIMENT
CONTROL
1: Does the State or local government require erosion and sediment control for construction
projects?
2: Does the State or local government have an erosion and sediment control requirement
that is different from the requirements of the NPDES storm water permit?
OTHER CONTROLS
GOOD HOUSEKEEPING
1: Does the facility appear to implement good housekeeping practices?
WASTE DISPOSAL
1: What steps are taken to ensure that construction waste is properly disposed of?
2: What management practices are used to minimize or prevent impacts on storm water
from hazardous products on the construction site?
3: Are concrete trucks allowed to washout or dump onsite?
4: Is sandblasting performed at the site? If so, what is done with the used grit?
MINIMIZING OFFSITE VEHICLE TRACKING OF SEDIMENTS
1: What measures have been taken to prevent offsite vehicle tracking?
SANITARY/SEPTIC DISPOSAL
1: How are sanitary or septic wastes managed?
2: How does the facility demonstrate compliance with State or local sanitary or septic
system regulations?
MATERIAL MANAGEMENT
1: What types of materials are found on the construction site?
2: How are these materials managed?
3: What risks are present onsite as a result of material management practices?
4: Is the facility implementing any methods to reduce potential risks from material
management?
5: If applicable, how are pesticides managed at the site?
6: If applicable, how are petroleum products managed at the site?
7: If applicable, what steps are taken to reduce nutrient pollution from fertilizers and
detergents?
SPILLS
1: Does the facility have a spill control plan for the site?
2: Does the facility know what spill prevention methods and responses will be used?
N-2
-------
Appendix N Construction Source Control BMP Questions
CONTROL OF ALLOWABLE NON-STORM WATER DISCHARGES
1: What non-storm water discharges are present at the site?
2: How does the facility manage the non-storm water discharges?
3: How are allowable non-storm water discharges addressed in the storm water Pollution
Prevention Plan?
4: What types of controls or practices are used to prevent pollution from non-storm water
discharges?
5: What types of controls are used for discharges that have sediments?
N-3
-------
-------
APPENDIX O
MONITORING REQUIREMENTS IN EPA'S
GENERAL PERMIT
-------
-------
Appendix O
Monitoring Requirements in EPA's General Permit
EPA FINAL GENERAL PERMIT MONITORING REQUIREMENTS1
)'V; * "ff ->- ,
tjiyp* of *ftoi$$t '
EPCRA, Section
313 Facilities
Subject to
Reporting
Requirements for
Water Priority
Chemicals
Primary Metal
Industries
(SIC 33)
Land Disposal
Units/ Incinerators/
BIFs
'" "-'C ^ ' Type of
Storm Water Discharge
Storm water discharges that come
into contact with any equipment,
tank, container, or other vessel or
area used for storage of a Section
313 water priority chemical, or
located at a truck or rail car loading
or unloading area where a Section
313 water priority chemical is
handled
All storm water discharges
associated with industrial activity
Storm water discharges from active
or inactive land disposal units
without a stabilized cover that have
received any waste from industrial
facilities other than construction
sites and storm water discharges
from incinerators and BIFs that burn
hazardous waste
, " ~\v '", - '
; \; <-' x "**'' " '
. Parlwetst^ J-
Oil and Grease, BOD5, COD,
TSS, Total Kjeldahl Nitrogen,
Total Phosphorus, pH, acute
whole effluent toxicity2, any
Section 313 water priority
chemical for which the facility
reports
Oil and Grease, COD, TSS,
pH, acute whole effluent
toxicity2, Total Recoverable
Lead, Total Recoverable
Cadmium, Total Recoverable
Copper, Total Recoverable
Arsenic, Total Recoverable
Chromium, and any pollutant
limited in an effluent
guideline to which the facility
is subject
Total Recoverable
Magnesium, Magnesium
(dissolved), Total Kjeldahl
Nitrogen (TKN), COD, TDS,
TOC, Oil and Grease, pH,
Total Recoverable Arsenic,
Total Recoverable Barium,
Total Recoverable Cadmium,
Total Recoverable
Chromium, Total Cyanide,
Total Recoverable Lead,
Total Mercury, Total
Recoverable Selenium, Total
Recoverable Silver, acute
whole effluent toxicity2
Monitoring
Frequency
Semi-
annual
Semi-
annual
Semi-
annual
Reporting
fftpfamet,
^.^ ^ •. .
Annual
Annual
Annual
O-1
-------
Appendix O
Monitoring Requirements in EPA's General Permit
EPA FINAL GENERAL PERMIT MONITORING REQUIREMENTS1
£' '' 's''{ ' * / ^ '\' C"~
Wood Treatment
Facilities
Facilities that use
chlorophenolic
formulations
Facilities that use
creosote
formulations
Facilities that use
chromium-arsenic
formulations
Industrial Facilities
with Coal Piles
Battery Reclaimers
Airports
(with over 50,000
flight operations
per year)
Coal-Fired Steam
Electric Facilities
Storm water discharges from areas
that are used for wood treatment,
wood surface application or storage
of treated or surface protected
wood
Storm water discharges from coal
pile runoff
Storm water discharges from areas
for storage of lead acid batteries,
reclamation products, or waste
products and from areas used for
lead acid battery reclamation
Storm water discharges from
aircraft or airport deicing areas
Storm water discharges from coal
handling sites (other than runoff
from coal piles, which is not eligible
for coverage under this permit)
Oil and Grease, pH, COD,
TSS
Plus Pentachlorophenol and
acute whole effluent toxicity2
Plus acute whole effluent
toxicity2
Plus Total Recoverable
Arsenic, Total Recoverable
Chromium, Total
Recoverable Copper
Oil and Grease, pH, TSS,
Total Recoverable Copper,
Total Recoverable Nickel,
Total Recoverable Zinc
Oil and Grease, COD, TSS,
pH, Total Recoverable
Copper, Total Recoverable
Lead
Oil and Grease, BOD5, COD,
TSS, pH, and the primary
ingredient used in the deicing
materials
Oil and Grease, pH, TSS,
Total Recoverable Copper,
Total Recoverable Nickel,
Total Recoverable Zinc
Semi-
annual
Semi-
annual
Semi-
annual
Annual
Annual
Annual
Annual
Annual
Retain
onsite
Retain
onsite
O-2
-------
Appendix O
Monitoring Requirements in EPA's General Permit
EPA FINAL GENERAL PERMIT MONITORING REQUIREMENTS1
:Vr*M>fofi^itt^
Animal Handling/
Meat Packing
Facilities
Chemical and
Allied Product
Manufacturers/
Rubber
Manufacturers
(SIC 28 and 30)
Automobile
Junkyards
Lime
Manufacturing
Facilities
Oil-fired Steam
Electric Power
Generating
Facilities
Cement
Manufacturing
Facilities and
Cement Kilns
$'&> *"-» 'fifei'^^r^f
f •Vft^W^tifemfo^'
Storm water discharges from animal
handling areas, manure
management areas, production
waste management areas exposed
to precipitation at meat packing
plants, poultry packing plants,
facilities that manufacture animal
and marine fats and oils
Storm water discharges that come
into contact with solid chemical
storage piles
Storm water discharges exposed to:
(a) over 250 auto/truck bodies with
drivelines, 250 drivelines, or any
combination thereof
(b) over 500 auto/truck units
(c) over 100 units dismantled per
year where automotive fluids are
drained or stored
Storm water discharges that have
come into contact with lime storage
piles
Storm water discharges from oil
handling sites
All storm water discharges
associated with industrial activity
(except those from material storage
piles that are not eligible for
coverage under this permit)
•<4\^ ,Pir^*fters , *
BOD5, Oil and Grease, COD,
TSS, TKN, Total
Phosphorus, pH, Fecal
Coliform
Oil and Grease, COD, TSS,
pH, any pollutant limited in
an effluent guideline to which
the facility is subject
Oil and Grease, COD, TSS,
pH, any pollutant limited in
an effluent guideline to which
the facility is subject
Oil and Grease, COD, TSS,
pH, any pollutant limited in
an effluent guideline to which
the facility is subject
Oil and Grease, COD, TSS,
pH, any pollutant limited in
an effluent guideline to which
the facility is subject
Oil and Grease, COD, TSS,
pH, any pollutant limited in
an effluent guideline to which
the facility is subject
Annual
Annual
Annual
Annual
Annual
Annual
*faH&&
*^p*«e?
Retain
onsite
Retain
onsite
Retain
onsite
Retain
onsite
Retain
onsite
Retain
onsite
O-3
-------
Appendix O
Monitoring Requirements in EPA's General Permit
EPA FINAL GENERAL PERMIT MONITORING REQUIREMENTS1
Cf* "i W^A^K,
:;„ .^itl-^i v1"-, t ^
Ready-mix
Concrete Facilities
Ship Building and
Repairing Facilities
^K:r^^Pi-"V W"'. '.'
(%; ; Sl9^|^^rtter^NNl^i8l|fr-; ;~^~
All storm water discharges
associated with industrial activity
All storm water discharges
associated with industrial activity
":'. - ,//«**''* '*•'.. '9,'^ •:''»''^'',i.i. "*'••
•.•••J&*'J#K PwRfwiBtelW- ., --^.«
Oil and Grease, COD, TSS,
pH, any pollutant limited in
an effluent guideline to which
the facility is subject
Oil and Grease, COD, TSS,
pH, any pollutant limited in
an effluent guideline to which
the facility is subject
Annual
Annual
' w * '• • '~'^".
Retain
onsite
Retain
onsite
1A discharger is not subject to the monitoring requirements provided the discharger makes a certification for a given
outfall, on an annual basis, under penalty of law, that material handling equipment or activities, raw materials,
intermediate products, final products, waste materials, by-products, industrial machinery or operations, significant
materials from past industrial activities, or, in the case of airports, deicing activities, that are located in areas of the
facility that are within the drainage area of the outfall, are not presently exposed to storm water, and will not be
exposed to storm water for the certification period.
2A discharger may, in lieu of monitoring for acute whole effluent toxicity, monitor for pollutants identified in Tables II
and III of Appendix D of 40 CFR Part 122 that the discharger knows or has reason to believe are present at the
facility site. Such determinations are to be based on reasonable best efforts to identify significant quantities of
materials or chemicals present at the facility. (Tables II and III of 40 CFR Part 122 Appendix D are provided
below.)
O-4
-------
Appendix O
Monitoring Requirements in EPA's General Permit
TABLE II. ORGANIC TOXIC POLLUTANTS IN EACH OF FOUR FRACTIONS IN ANALYSIS
BY GAS CHROMATOGRAPHY/MASS SPECTROSCOPY (GS/MS)
Volatiles
1V
2V
3V
5V
6V
7V
8V
9V
10V
11V
acrolein
acrylonitrile
benzene
bromoform
carbon tetrachloride
chlorobenzene
chlorodibromomethane
chloroethane
2-chloroethylvinyl ether
chloroform
12V
14V
15V
16V
17V
18V
19V
20V
21V
dichlorobromomethane
1,1-dichloroethane
1,2-dichloroethane
1,1-dichloroethylene
1 ,2-dichloropropane
1 ,3-dichloropropylene
ethylbenzene
methyl bromide
methyl chloride
22V
23V
24V
25V
26V
27V
28V
29V
31V
methylene chloride
1 ,1 ,2,2-tetrachloroethane
tetrachlororoethylene
toluene
1 ,2-trans-dichloroethylene
1,1,1-trichloroethane
1 ,1 ,2-trichloroethane
trichloroethylene
vinyl chloride
Acid Compounds
1A
2A
3A
4A
2-chlorophenol
2,4-dichlorophenol
2,4-dimethylphenol
4,6-dinitro-o-cresol
5A
6A
7A
8A
2,4-dinitrophenol
2-nitrophenol
4-nitrophenol
p-chloro-m-cresol
9A
10A
11A
pentachlorophenol
phenol
2,4,6-trichlorophenol
Base/Neutral
1B
2B
3B
4B
5B
6B
7B
8B
9B
10B
11B
12B
13B
14B
15B
16B
acenaphthene
acenaphthylene
anthracene
benzidine
benzo(a)anthracene
benzo(a)pyrene
3,4-benzofluoranthene
benzo(ghi)perylene
benzo(k)fluoranthene
bis(2-chloroethoxy)methane
bis(2-chloroethyl)ether
bis(2-chloroisopropyl)ether
bis(2-ethylhexyl)phthalate
4-bromophenyl phenyl ether
butylbenzyl phthalate
2-chloroanaphthalene
17B
18B
19B
20B
21B
22B
23B
24B
25B
26B
27B
28B
29B
SOB
31B
4-chlorophenyl phenyl ether
. chrysene
dibenzo(a,h)anthracene
1 ,2-dichlorobenzene
1 ,3-dichlorobenzene
1 ,4-dichlorobenzene
3,3'-dichlorobenzidene
diethyl phthalate
dimethyl phthalate
di-n-butyl phthalate
2,4-dinitrotoluene
2,6-dinitrotoluene
di-n-octyl phthalate
1 ,2-diphenylhydrazine (as
azobenzene)
fluroranthene
32B
33B
34B
35B
36B
37B
38B
39B
40B
41B
42B
43B
44B
45B
46B
fluorene
hexachlorobenzene
hexachlorobutadiene
hexachlorocyclopentadiene
hexachloroethane
indeno(1 ,2,3-cd)pyrene
isophorone
naphthalene
nitrobenzene
N-nitrosodimethylamine
N-nitrosodi-n-propylamine
N-nitrosodiphenylamine
phenanthrene
pyrene
1 ,2,4-trichlorobenzene
Pesticides
1P
2P
3P
4P
5P
6P
7P
8P
9P
aldrin
alpha-BHC
beta-BHC
gamma-BHC
delta-BHC
chlordane
4,4'-DDT
4,4'-DDE
4,4'-DDD
10P
11P
12P
13P
14P
15P
16P
17P
dieldrin
alpha-endosulfan
beta-endosulfan
endosulfan sulfate
endrin
endrin aldehyde
heptachlor
heptachlor epoxide
18P
19P
20P
21 P
22P
23P
24P
25P
PCB-1242
PCB-1254
PCB-1221
PCB-1232
PCB-1248
PCB-1260
PCB-1016
toxaphene
TABLE III. OTHER TOXIC POLLUTANTS (METALS AND CYANIDE) AND TOTAL PHENOLS
Antimony, Total
Arsenic, Total
Beryllium, Total
Cadmium, Total
Chromium, Total
Copper, Total
Lead, Total
Mercury, Total
Nickel, Total
Selenium, Total
Silver, Total
Thallium, Total
Zinc, Total
Cyanide, Total
Phenols, Total
O-5
-------
-------
APPENDIX P
RAIN ZONES OF THE UNITED STATES
-------
Appendix P
Rain Zones of the United States
Figure P-1
Rain Zones of the United States
461B-14
Table P-1.
Typical Values of Annual Storm Event Statistics for Rain Zones
Annual Statistics
Independent Storm Event Statistics
Rain Zone
North East
North East-Coastal
Midatlantic
Central
North Central
Southeast
East Gulf
East Texas
West Texas
Southwest
West Inland
Pacific South
Northwest Inland
Pacific Central
Pacific Northwest
No. of Storms
Avg
70
63
62
66
55
65
68
41
30
20
14
19
31
32
71
cov
0.13
0.12
0.13
0.14
0.16
0.15
0.17
0.22
0.27
0.30
0.38
0.36
0.23
0.25
0.15
Precip
Avg
(in)
34.6
41.4
39.5
41.9
29.8
49.0
53.7
31.2
17.3
7.4
4.9
10.2
11.5
18.4
56.7
COV
0.18
0.21
0.18
0.19
0.22
0.20
0.23
0.29
0.33
0.37
0.43
0.42
0.29
0.33
0.19
Duration
Avg
(hrs)
11.2
11.7
10.1
9.2
9.5
8.7
6.4
8.0
7.4
7.6
9.4
11.6
10.4
13.7
15.9
COV
0.81
0.77
0.84
0.85
0.83
0.92
1.05
0.97
0.98
0.88
0.75
0.76
0.82
0.80
0.80
Intensity
Avg
(in/hr)
0.067
0.071
0.082
0.097
0.067
0122
0.176
0.137
0.121
0.079
0.055
0.054
0.057
0.048
0.035
COV
1.23
1.05
1.20
1.09
1.20
1.09
1.03
1.08
1.13
1.16
1.06
0.76
1.20
0.85
0.73
Volume
Avg
(in)
0.50
065
0.64
0.62
0.55
0.75
0.80
0.76
0.57
0.37
0.36
0.54
0.37
0.58
0.50
COV
0.95
1.03
1.01
1.00
1.01
1.10
1 19
1.16
1.07
0.88
0.87
0.96
0.83
1 05
1.09
DELTA
Avg
(hr)
126
140
143
133
167
136
130
213
302
473
766
476
304
265
123
COV
0.94
0.87
0.97
099
1.17
1 03
1.25
1.26
1.53
1.46
1.54
2.09
1 43
2.00
1.50
COV - Coefficient of Variation - Standard Deviation / Mean
DELTA - Interval between storm midpoints
P-1
-------
APPENDIX Q
TYPICAL "c" COEFFICIENTS
-------
Appendix Q
Typical "c" Coefficients
TYPICAL "c" COEFFICIENTS
FOR 5- TO 10-YEAR FREQUENCY DESIGN STORMS
Description of Area
Runoff Coefficients
Business
• Downtown areas
• Neighborhood areas
Residential
• Single-family areas
• Multi-units (detached)
• Multi-units (attached)
Residential (suburban)
Apartment dwelling areas
Industrial
• Light areas
• Heavy areas
Parks and cemeteries
Playgrounds
Railroad yard areas
Unimproved areas
Streets
• Asphalt
• Concrete
• Brick
Drives and walks
Roofs
Lawns—course textured soil (greater than 85 percent
sand)
• Slope: Flat (2 percent)
Average (2-7 percent)
Steep (7 percent)
Lawns—fine textured soil (greater than 40 percent clay)
• Slope: Flat (2 percent)
Average (2-7 percent)
Steep (7 percent)
0.70-0.95
0.50-0.70
0.30-0.50
0.40-0.60
0.60-0.75
0.25-0.40
0.50-0.70
0.50-0.80
0.60-0.90
0.10-0.25
0.20-0.35
0.20-0.40
0.10-0.30
0.70-0.95
0.80-0.95
0.70-0.85
0.75-0.85
0.75-0.95
0.05-0.10
0.10-0.15
0.15-0.20
0.13-0.17
0.18-0.22
0.25-0.35
Source: Design and Construction of Sanitary and Storm Sewers, with permission from the
publisher, American Society of Civil Engineers, Manual of Practice, page 37, New York,
1960.
Q-1
-------
Appendix Q Typical "c" Coefficients
Q-2
-------
APPENDIX R
POLLUTION PREVENTION CHECKLISTS
-------
Appendix R Pollution Prevention Checklist
A. Pollution Prevention Checklist for
Industry
General
Is there a written facility policy regarding pollution prevention?
Is there a pollution prevention program currently in place?
Is there a specific person assigned to oversee the success of the program?
Are there management/employee initiatives and incentive programs related to pollution
prevention?
If yes, do these include:
• Quality circles (free forums between employees and supervisors) to identify pollution
prevention options?
• Opportunities for employee suggestions on pollution prevention options?
Has the facility previously conducted a pollution prevention assessment?
Has the facility used better cost accounting and cost allocation to provide incentives to reduce
wastes or resource consumption?
• Is cost accounting performed accurately for all process areas and wastestreams?
• Are utility costs (energy, water) and waste treatment and disposal costs allocated to
the operations that generate the waste?
Storage Areas
Are there designated material storage areas?
Are storage areas clean and organized?
Are containers stored in such a way as to allow for visual inspection for corrosion and/or
leaks?
Are containers stacked in a way to minimize the chance of tipping, puncturing, or breaking?
R-1
-------
Appendix R Pollution Prevention Checklist
Are there adequate distances from incompatible chemicals and different types of chemicals to
prevent cross-contamination?
Is one person responsible for maintaining storage areas?
Does the layout of the facility result in minimizing traffic through material storage areas?
Are stored items protected from damage, contamination, and exposure to weather?
Are all storage tanks routinely monitored for leaks?
Is containment, such as a curb or dike, installed in storage areas to contain leakage and to
minimize the area contaminated by a spill?
Are leak detection systems installed for underground storage tanks?
Are floating-roof tanks used for VOC control?
Are conservation vents used on fixed roof tanks?
Does the facility use vapor recovery systems?
Materials Inventory
Is there an inventory control system designed to prevent materials from deteriorating in
storage (first in, first out to prevent expiration)?
Is obsolete raw material returned to the supplier?
Does the facility try to order smaller containers of infrequently used materials to avoid
disposing of large quantities of unused obsolete materials?
Has the facility tried to order larger containers of frequently used materials to reduce the
number of small containers that must be cleaned and disposed of?
Does the facility use or maintain:
• Hazardous chemicals inventory lists?
• Material safety data sheet files?
Are all in-plant containers of hazardous chemicals labeled, tagged, or marked with:
• Identity of the hazardous chemical(s)?
• Appropriate hazard warnings?
Has the facility reexamined its need for each raw material?
Does the facility have a way to use off-spec material, where possible?
R-2
-------
Appendix R Pollution Prevention Checklist
Material Handling
Are raw materials tested for quality before being accepted from suppliers?
Does the facility follow proper procedures when transferring materials?
Are expired materials tested for effectiveness before being disposed of?
Are drums, packages, and containers inspected for damage before being accepted?
Are containers properly reseated after use?
Are containers emptied thoroughly before cleaning or disposal?
Does the facility segregate its wastes as much as possible:
• Solid wastes from aqueous wastes?
• Nonhazardous from hazardous?
• Segregated according to type of contaminant?
• Different types of solid waste to improve recycling/reuse?
• Different types of solvents, cleaner wastes, and lubricants (e.g., organic solvents from
mineral oils)?
Process Operations
Are water conservation measures, recycling, and reuse techniques practiced in processes that
use water or generate a wastewater (e.g., cleaning and rinsing operations)?
Has material substitution been tried for any hazardous materials used in process?
Have any techniques been used to increase the life of any process baths?
Are any wastes being recycled, reused, or recovered in some manner?
Have any equipment or process modifications been made to increase material use efficiency
and thus reduce material waste generation?
Do processes employ any detectors to alert personnel of malfunctions that could
produce/generate excessive wastes?
R-3
-------
Appendix R Pollution Prevention Checklist
Spills and Leaks
When a spill occurs:
• What cleanup methods are employed?
• Would different cleaning methods allow for direct reuse or recycling of the water?
Are there preventative maintenance procedures designed to reduce incidents of equipment
breakdowns, inefficiency, spills, or leaks?
Material Substitution
Could the facility modify or completely change a given process to use water-based coolants
and fluids instead of oil-based fluids?
Solvent Use
Can solvent cleaning be replaced with less toxic cleaning, such as:
• A dry process (e.g., bead or sand blasting or other abrasives)?
• Steam cleaning?
• Cryogenic?
• Caustic cleaning?
Are non-chlorinated solvents substituted for chlorinated solvents?
Are parts wiped to remove oil and dirt prior to solvent cleaning?
Is the loss of cleaning ability of the solvent monitored before the solvent is replaced?
Are solvents reused or recycled?
Is an onsite distillation unit for solvent recovery and reuse installed?
Is solvent use standardized?
Rinse Waters
Have excessive rinses been evaluated and eliminated?
Is rinse water reclaimed, pretreated, and reused?
R-4
-------
Appendix R Pollution Prevention Checklist
Are water softeners used only where necessary?
Training
Are there formal personnel training programs on raw material handling, spill prevention, proper
storage techniques, and waste handling procedures?
Are employees trained in pollution prevention techniques?
How often is training given and by whom?
Good Operating Practices
Are plant material balances performed routinely?
Are they performed separately for each material of concern?
Are records kept for each waste, documenting sources of origin and eventual disposal?
Are operators provided with detailed operating manuals or instruction sets?
Are all operator job functions well defined?
Are regularly scheduled training programs offered to operators?
Has the facility integrated pollution prevention into supervision and management by:
• Closer supervision to improve production efficiency and reduce inadvertent waste
generation (increased opportunity for early detection of mistakes)?
• Management By Objectives (MBO) with defined and achievable goals for waste
minimization (better coordination among the various parts of an overall operation)?
Has the facility improved production scheduling and planning to include:
• Maximizing batch sizes
• Dedicating equipment to a single product
• Altering batch sequencing to minimize cleaning frequency
• Scheduling production to minimize cleaning frequency?
Is corrective maintenance practiced, such as resetting control valves or adjusting process
temperatures, to increase efficiency and to prevent raw material loss through waste streams?
Does the facility forbid operators to bypass interlocks and alarms, or to significantly alter
setpoints without authorization?
R-5
-------
Appendix R Pollution Prevention Checklist
Are overflow or malfunction alarms installed on tanks and equipment?
Housekeeping Practices
Good housekeeping is the maintenance of a clean, orderly work environment. Does the
facility:
• Maintain neat and orderly storage of chemicals?
• Promptly remove spillage?
• Maintain dry and clean floors by use of brooms and/or vacuum cleaners?
• Provide proper walkways with no containers protruding into walkways?
• Minimize the accumulation of liquid and solid chemicals on the ground or floor?
• Stimulate employee interest in good housekeeping?
Checklist derived from Waste Reduction Assessment and Technology Transfer (WRATT)
Training Manual. 2nd Edition, University of Tennessee
R-6
-------
Appendix R Pollution Prevention Checklist
B. Pollution Prevention Checklist for
Municipal Wastewater Treatment
Plants
Age
What year was the wastewater treatment plant constructed or the last major expansion to
increase the capacity of the plant completed?
What sewerage system improvements does the municipality have under consideration for the
next 10 years?
What is the expected community and industrial growth? Is there any major development
(industrial, commercial, or residential) anticipated in the next 2 to 3 years, such that either the
flow or pollutant loadings could significantly increase?
Treatment Efficiency
Compare influent actual flow to influent design flow. When will actual hydraulic loading
exceed design?
• Has the plant initiated expansion plans and financing sufficiently in advance to avoid
overloading?
• Has the plant investigated measures for reducing flow?
Compare conventional pollutant loadings (BOD, TSS, ammonia, phosphorus) to design
loadings. When will actual loadings exceed design?
• Has the plant initiated expansion plans and financing sufficiently in advance to avoid
overloading?
• Has the plant investigated measures for reducing loadings?
Review operating records. How many months were the effluent concentrations or loadings
above 90 percent of the permit limits?
BOD?
COD?
Fecal coliform?
Other conventional pollutants limited by permit (ammonia, phosphorus)?
Metals or other toxics?
R-7
-------
Appendix R Pollution Prevention Checklist
How many times were permit limits violated (in the last year)?
What types of violations have occurred in the last 5 years?
• Are any of a recurrent nature?
• What were the causes?
• Have effective solutions been implemented to prevent future recurrence?
How many bypasses have occurred?
• What were the causes?
• Have effective solutions been implemented to prevent future recurrence?
What are the future regulatory or permit requirements that may require modifications to the
plant or its operations?
• Can the facility currently meet any future anticipated water quality standards or effluent
discharge limits?
Has the plant investigated ways to maximize operating efficiency?
Has the plant investigated improvements to the chlorination system to decrease chlorine
usage?
Sludge
Does the plant have sufficient sludge treatment, storage, and disposal capacity?
What percentage of the methane gas is captured and used? Has the plant investigated ways
to increase the amount of gas captured and used?
Has the plant investigated ways to decrease the amount of dewatering chemicals used?
Collection System
How many overflows within the collection system have occurred?
How many backups at any point in the collection system have occurred for any reason?
• What were the causes?
• Have effective solutions been implemented to prevent future recurrence?
Has the plant investigated ways to decrease infiltration/inflow?
R-8
-------
Appendix R Pollution Prevention Checklist
Preventive Maintenance Program
Does the plant have a written preventive maintenance program on major equipment items and
the sewer collection system?
Does the preventive maintenance program depict frequency of intervals, types of lubrication,
types of repair and other preventive maintenance tasks necessary for each piece of
equipment or each section of the sewer?
Are these preventive maintenance tasks, as well as equipment and sewer collection problems
being recorded, filed, and reviewed so future maintenance problems can be assessed
properly?
Materials Usage
Has the plant identified all supplies used in the operation and maintenance of the plant?
Has the plant identified materials that could be substituted for less toxic materials?
Does the plant reuse or recycle any materials used?
Has the plant investigated ways to reduce chemical usage without compromising preventive
maintenance or treatment?
Personnel Resources
Review personnel resources, training, and certifications. Are there sufficient numbers.. Do all
have appropriate certifications and periodic training?
• Do all personnel certifications meet or exceed required levels?
- How many are below required level?
• Is staffing level equal to or does it exceed O & M manual recommendations?
What percentage of the wastewater budget is dedicated for training?
Financial
Are the funds for the plant separate from other municipal funds?
Are funds sufficient for adequate operations?
Are funds sufficient for adequate preventive maintenance?
R-9
-------
Appendix R Pollution Prevention Checklist
Are funds available for necessary improvements, expansion?
Is there a capital improvement fund?
Is the equipment replacement fund in a segregated account?
What financial resources are available to pay for improvements/expansion/reconstruction?
Municipal Pollution Prevention Projects
Does the plant have a pollution prevention program or strategy?
Has the plant conducted a self-audit on the adequacy of its maintenance, operation, funding,
and operator training?
Does the pretreatment program include a pollution prevention component or specific pollution
prevention projects?
Does the municipality have any pollution prevention projects aimed at reducing
toxic/hazardous waste discharges, conventional loadings, or flow (e.g., water conservation)
from:
• Households?
• Commercial businesses?
• Industries?
R-10
-------
APPENDIX S
MEDIA-SPECIFIC INSPECTION COMPONENTS
EXCERPTED (AND UPDATED) FROM EPA'S
MULTIMEDIA INVESTIGATION MANUAL
-------
Appendix S Media-Specific Inspection Components
The information in this appendix was excerpted from NEIC's Multimedia
Investigation Manual
The information presented in this appendix includes many significant tasks for several media-
specific inspection areas. Media discussed include hazardous waste, air, drinking water, toxic
substances, and pesticides; emergency planning/community right-to-know and the Superfund
program are also discussed.
A. Resource Conservation and
Recovery Act (RCRA)
Subtitle C Hazardous Wastes
Evaluating Compliance
Under RCRA Subtitle C, hazardous wastes are subject to extensive regulations on generation,
transportation, storage, treatment, and disposal. A manifest system tracks shipments of
hazardous wastes from the generator through ultimate disposal. This "cradle to grave"
management is implemented through regulations and permits.
In determining the facility status under RCRA, the investigator must decide whether the facility
is a generator, transporter, and/or Treatment, Storage, and Disposal Facility (TSDF), and
whether the facility is permitted or has interim status. Generally, EPA Regional and State
offices maintain files for the facility to be inspected. Information may include:
• A list of wastes that are treated, stored, and disposed and how each is managed (for
TSDFs)
• A list of hazardous wastes generated, their origins, and accumulation areas (for
generators)
• Biennial, annual, or other reports required by RCRA and submitted to the regulatory
agencies; these include any required monitoring reports
• A detailed map or plot plan showing the facility layout and location(s) of waste
management areas
• The facility RCRA Notification Form (Form 8700-12)
• The RCRA Part A Permit Application (for TSDFs)
• The RCRA Part B Permit application (for TSDFs, if applicable)
S-1
-------
Appendix S Media-Specific Inspection Components
• The RCRA permit (for TSDFs, if applicable)
• Notifications and/or certifications for land disposal restrictions (for generators).
Generators
Hazardous waste generators are regulated under 40 CFR Parts 262 and 268. These
regulations contain requirements for:
• Obtaining an Environmental Protection Agency (EPA) Identification Number
• Determining whether a waste is hazardous
• Managing wastes before shipment
• Accumulating and storing hazardous wastes
• Manifesting waste shipments
• Recordkeeping and reporting
• Restricting wastes from land disposal (also regulated under Part 268).
The generator regulations vary, depending upon the volume of hazardous wastes generated.
The investigator must determine which regulations apply. Additionally, the investigator should
do the following:
• Verify that the generator has an EPA Identification Number that is used on all required
documentation (e.g., reports, manifests, etc.).
• Confirm that the volume of hazardous wastes generated is consistent with reported
volumes. Examine the processes generating the wastes to assure that all generated
hazardous wastes have been identified. Look for improper mixing or dilution.
• Ascertain how the generator determines/documents that a waste is hazardous. Check
to see wastes are properly classified. Collect samples, if necessary.
• Determine whether pre-transport requirements are satisfied, including those for
packaging, container condition, labeling and marking, and placarding.
• Determine the length of time that hazardous wastes are being stored or accumulated.
Storage or accumulation for more than 90 days requires a permit. Generators storing
for less than 90 days must comply with requirements outlined in 40 CFR 262.34.
• Verify RCRA reports and supporting documentation for accuracy, including inspection
logs, biennial reports, exception reports, and manifests (with land disposal restriction
notifications and/or certifications).
• Watch for accumulation areas which are in use but have not been identified by the
generator. Note: Some authorized State regulations do not have provisions for
"satellite storage" accumulation areas.
S-2
-------
Appendix S Media-Specific Inspection Components
• Determine whether a generator has the required contingency plan and emergency
procedures, whether the plan is complete, and if the generator follows the plan/
procedures.
• Determine whether hazardous waste storage areas comply with applicable
requirements.
• Facilities with their own vehicle maintenance garage should be evaluated to assure
that wastes such as used oil, anti-freeze, solvents, and paints are disposed of properly.
Transporters
Hazardous waste transporters (e.g., by truck, ship, or rail) are regulated under 40 Code of
Federal Regulations CFR Part 263, which contains requirements for:
• Obtaining an EPA Identification-Number
• Manifesting hazardous waste shipments
• Recordkeeping and reporting
• Sending bulk shipments (by water, rail).
Storage regulations apply if accumulation times at transfer stations are exceeded.
Transporters importing hazardous wastes, or mixing hazardous wastes of different Department
of Transportation (DOT) shipping descriptions in the same container, are classified as
generators and must comply with 40 CFR Parts 262 and 268. Investigators evaluating
transporter compliance should do the following:
• Verify that the transporter has an EPA identification number that is used on all required
documentation (e.g., manifests).
• Determine whether hazardous waste containers stored at a transfer facility meet DOT
pre-transport requirements.
• Verify whether the transporter is maintaining recordkeeping and reporting documents,
including manifests, shipping papers (as required), and discharge reports. All required
documents should be both present and complete.
Treatment, Storage, and Disposal Facilities
Permitted and interim status TSDFs are regulated under 40 CFR Parts 264 and 265,
respectively. (Part 264 applies only if the facility has a RCRA permit (i.e., a permitted facility);
Part 265 applies if the facility does not have a RCRA permit (i.e., an interim status facility).
These requirements include three categories of regulations consisting of administrative
requirements, general standards, and specific standards. The investigator should do the
following activities to determine compliance with Subparts A through E:
• Verify that the TSDF has an EPA Identification Number that is used on all required
documentation.
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• Determine what hazardous wastes are accepted at the facility, how they are verified,
and how they are managed.
• Compare wastes managed at the facility with those listed in the Hazardous Waste
Activity Notification (Form 8700-12), the Parts A and B permit applications, and the
permit.
• Verify that the TSDF has and is following a waste analysis plan kept at the facility;
inspect the plan contents.
• Identify and inspect security measures and equipment.
• Review inspection logs to ensure they are present and complete. Note problems and
corrective measures.
• Review training documentation to ascertain that required training has been given to
employees.
• Inspect waste management areas to determine whether reactive, ignitable, and
incompatible wastes are handled pursuant to requirements.
• Review preparedness and prevention practices and inspect related equipment.
• Review contingency plans; examine emergency equipment and documented
arrangements with local authorities.
• Examine the waste tracking system and associated recordkeeping/reporting systems.
Required documentation includes manifests and biennial reports, and may include
unmanifested waste reports and spill/release reports. Relevant documents may
include on-site waste tracking forms.
• Verify that the operating record is complete according to 40 CFR 264.73 or 265.73.
The investigator can determine compliance with standards in Subparts F through H by doing
the following:
• For permitted facilities, verify compliance with permit standards with respect to ground
water monitoring, releases from solid waste management units, closure/post-closure,
and financial requirements.
• For interim status facilities required to monitor ground water, determine what kind of
monitoring program applies.
• Depending on the type of investigation, examine the following items to determine
compliance:
- Characterization of site hydrogeology
- Sampling and analytical records
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- Statistical methods used to compare analytical data
- Analytical methods
- Compliance with reporting requirements and schedules
- Sampling and analysis plan (for content, completeness, and if it is being followed)
- Conditions, maintenance, and operation of monitoring equipment, including
wellheads, field instruments, and sampling materials
- Construction/design of monitoring system
- Assessment monitoring outline and/or plan
- Corrective action plan for permitted facilities and for interim status facilities under
3008(h) enforcement actions.
• For waste management units undergoing closure, review the closure plan (including
amendments and modifications), plan approval, closure schedule, and facility and
regulatory certification. Examine response actions to any release of hazardous waste
constituents from a closed or closing regulated unit.
• For waste management units in post closure care, inspect security measures, ground
water monitoring and reporting, and the maintenance and monitoring of waste
containment systems.
• Verify that the owner/operator has demonstrated financial assurance regarding closure.
Specific Hazardous Waste Management Units
The technical standards in Part 264 (Subparts I through O and Subpart X) and Part 265
(Subparts I through R) govern specific hazardous waste management units used for storage,
disposal, or treatment (e.g., tanks, landfills, incinerators). Standards for chemical, physical,
and biological treatment at permitted facilities under Part 264 have been incorporated under
Miscellaneous Units, Subpart X. The investigator should do the following:
• Identify all hazardous waste management areas and the activity in each area; compare
the areas identified in the field with those listed the permit or permit application, as
appropriate. Investigate inconsistencies between actual practice and the information
submitted to regulatory agencies.
• Verify that the owner/operator is complying with applicable design, installation, and
integrity standards; field-check the design, condition, and operation of waste
management areas and equipment.
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• Determine how incompatible wastes and ignitable or reactive wastes are managed.
• Verify that the owner/operator is conducting self-inspections where and when required;
determine what the inspections include.
• Identify and inspect required containment facilities for condition and capacity; identify
lead detection facilities.
• Determine whether hazardous waste releases have occurred and how the owner/
operator responds to leaks and spills.
• Verify that the owner/operator is complying with additional waste analysis and trial test
requirements, where applicable.
• Check the closure/post-closure procedures for specific waste management units
(surface impoundments, waste piles, etc.) for regulatory compliance.
• For landfills, determine how the owner/operator manages bulk and contained liquids.
• Field-check security and access to waste management units.
• Determine the facility monitoring requirements (for air emissions, ground water, leak
detection, instrumentation, equipment, etc.) and inspect monitoring facilities and
records.
Land Treatment Facilities
When inspecting land treatment facilities, the investigator should also review the following
items:
• Soil monitoring methods and analytical data.
• Comparisons between soil monitoring data and background concentrations of
constituents in untreated soils to detect migration of hazardous wastes.
• Waste analyses done to determine toxicity, the concentrations of hazardous waste
constituents, and, if food-chain crops are grown on the land, the concentrations of
arsenic, cadmium, lead, and mercury in the waste(s). The concentrations must be
such that hazardous waste constituents can be degraded, transformed, or immobilized
by treatment.
• Runon and runoff management systems.
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Incinerators
When evaluating compliance of interim status incinerators, the investigator also should review
and/or inspect the following items:
• Waste analyses done to enable the owner/operator to establish steady-state operating
conditions and to determine the pollutants that might be emitted.
• General procedures for operating the incinerator during start-up and shut-down.
• Operation of equipment used for monitoring combustion and emissions control,
monitoring schedules, and data output.
• The incinerator and associated equipment.
For permitted incinerators, the investigator must evaluate the incinerator operation against
specific permit requirements for waste analysis, performance standards, operating
requirements, monitoring, and inspections. The investigator also should do the following:
• Verify that the incinerator burns only wastes specified in the permit
• Verify methods to control fugitive emissions
• Determine waste management practices for burn residue and ash.
Thermal Treatment Facilities
The investigator evaluating compliance of thermal treatment facilities in interim status also
should review the following items:
• General operating requirements, to verify whether steady-state operating conditions are
achieved, as required.
• Waste analysis records, to ensure that (a) the wastes are suitable for thermal
treatment and (b) the required analyses in Part 265.375 have been performed.
Thermal treatment facilities permitted under 40 CFR Part 264 Subpart X will have specific
permit requirements.
Biological Treatment Facilities
The investigator evaluating compliance of chemical, physical, and biological treatment facilities
in interim status also should do the following:
• Determine the general operating procedures.
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• Review the waste analysis records and methods to determine whether the procedures
are sufficient to comply with 40 CFR 265.13.
• Review trial treatment test methods and records to determine whether the selected
treatment method is appropriate for the particular waste.
• Examine procedures for treating ignitable, reactive, and incompatible wastes for
compliance with Subpart Q requirements.
Chemical, physical, and biological treatment facilities permitted under Subpart X will have
specific permit requirements.
TSDF Air Emission Standards
Owners/operators of TSDFs must also comply with air emission standards contained in
Subparts AA and BC of 40 CFR Parts 264 and 265. These subparts establish standards for
equipment containing or contacting hazardous wastes with organic concentrations of at least
10 percent. This equipment includes:
• Process vents
• Pumps in light liquid service
• Compressors
• Sampling connecting systems
• Open-ended valves or lines
• Valves in gas/vapor service or in light liquid service
• Pumps and valves in heavy liquid service, pressure relief devices in light liquid or
heavy liquid service, and flanges and other connections.
Total organic emissions from process vents must be reduced below 1.4 kg/hr and 2.8 mg/yr.
The other equipment types above must be marked and monitored routinely to detect leaks.
Repairs must be initiated within 15 days of discovering the leak.
The facility operating record should contain information documenting compliance with the air
emission standards. A complete list of required information is in 40 CFR 264.1035, 264.1064,
265.1035, and 265.1064. Permitted facilities must submit semiannual reports to the Regional
Administrator outlining which valves and compressors were not fixed during the preceding 6
months. The investigator can do the following things:
• Visually inspect the equipment for marking.
• Review documentation in the operating record and cross-check this information with
that submitted to the Regional Administrator in semiannual reports.
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Land Disposal Restrictions
Land Disposal Restrictions (LDR) in 40 CFR Part 268 are phased regulations prohibiting land
disposal of hazardous wastes unless the waste meets applicable treatment standards as listed
in 40 CFR 268.40-43. The treatment standards are expressed as (1) contaminant
concentrations in the extract or total waste or (2) specified technologies.
Notifications and certifications comprise the majority of required LDR documentation.
Notifications tell the treatment or storage facility the appropriate treatment standards and any
prohibition levels (California List wastes) that apply to the waste. Certifications are signed
statements telling the treatment or storage facility that the waste already meets the applicable
treatment standards and prohibition levels.
The regulations divide hazardous wastes into restricted waste groups and apply a compliance
schedule of different effective dates for each group (40 CFR Part 268, Appendix VII).
Investigators evaluating hazardous waste generators for LDR compliance should do the
following:
• Determine whether the generator produces restricted wastes; review how/if the
generator determines a waste is restricted.
• Review documentation/data used to support the determination that a waste is
restricted, based solely on knowledge.
• Determine how/if a generator determines the waste treatment standards and/or
disposal technologies.
• Verify whether the generator satisfies documentation, recordkeeping, notification,
certification, packaging, and manifesting requirements.
• Ascertain whether the generator is, or might become, a TSDF and subject to additional
requirements.
• Determine who completes and signs LDR notifications and certifications and where
these documents are kept.
• Review the waste analysis plan if the generator is treating a prohibited waste in tanks
or containers.
Investigators evaluating TSDFs should do the following:
• Ensure the TSDF is complying with generator recordkeeping requirements when
residues generated from treating restricted wastes are manifested offsite.
• Verify whether the treatment standards have been achieved for particular wastes prior
to disposal.
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Review documentation required for storage, treatment, and land disposal;
documentation may include waste analyses and results, waste analysis plans, and
generator and treatment facility notifications and certifications.
Subtitle I—Underground Storage Tanks (USTs)
Evaluating Compliance
Because the tanks are located underground, visual/field observations have limited application
in determining compliance for USTs. The UST program relies heavily on the use of
documents to track the status and condition of any particular tank.
Interviews with facility personnel are important when determining compliance with any
environmental regulation. Questions regarding how the facility is handling its UST program
will give the inspector insight into the types of violations that may be found. Topics to be
covered in the interview include:
• Age, quantity, and type of product stored for each onsite tank.
• How and when tanks have been closed.
• Type of release detection used on each tank (if any); some facilities may have release
detection on tanks where it is not required.
• Type of corrosion protection and frequency of inspections.
• Which tanks have pressurized piping associated with them.
Visual/field observations are used to determine if any spills or overfills have occurred that
have not been immediately cleaned up. The presence of product around the fill pipe indicates
a spill or overfill. Proper release detection methods can also be verified with field
observations. During the interviews, ask the facility if monthly inventory control along with
annual tightness testing is used. If monthly inventory control is used, check the measuring
stick for divisions of 1/8 inch. A field check of the entire facility can also be done to determine
if any tanks may have gone unreported. Fillports and vent lines can indicate the existence of
a UST.
Documents take up the largest portion of time during a UST inspection. Documents that
should be reviewed include:
• Notifications for all UST systems
• Reports of releases including suspected releases, spills and overfills, and confirmed
releases
• Initial site characterization and corrective action plans
• Notifications before permanent closure
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• Corrosion expert's analysis if corrosion protection is not used
• Documentation of operation of corrosion protection equipment
• Recent compliance with release detection requirements, including daily inventory
sheets with the monthly reconciliation
• Results of site investigation conducted at the time of permanent closure.
Document retention rules also apply, so be sure to get all of the documents a facility may be
required to keep. To determine if the implementing agency has been notified of all tanks,
compare the notifications to general UST lists from the facility. Usually, the facility will keep a
list of tanks separate from the notifications and tanks may appear on that list that do not
appear on a notification form. Also, compare the notifications to tank lists required in other
documents, like the Spill Prevention Control and Countermeasures Plan.
Subtitle J—Medical Wastes
Subtitle J was added to RCRA in November 1988 to address concerns about the management
of medical wastes. EPA enacted interim final regulations in March 1989. The regulations,
found in 40 CFR Part 259, establish a demonstration program with requirements for medical
waste generators, transporters, and Treatment, Destruction, and Disposal Facilities (TDDFs).
The demonstration program was effective during the period June 22, 1989, to June 22, 1991.
The regulations applied to regulated medical wastes generated in Connecticut, New Jersey,
New York, Rhode Island, and Puerto Rico.
Basic Program
Medical waste is defined in 40 CFR 259.10 as any solid waste generated in the diagnosis,
treatment, or immunization of human beings or animals, in related research, biological
production, or testing. The following are exempt from 40 CFR Part 259 requirements;
• Any hazardous waste identified or listed under 40 CFR Part 261
• Any household waste defined in 40 CFft261.4(b)(1)
• Residues from treatment and destruction processes or from the incineration of
regulated medical wastes
• Human remains intended to be buried or cremated
• Etiologic agents being shipped pursuant to the Federal regulations
• Samples of regulated medical waste shipped for enforcement purposes.
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Regulated medical waste is a subset of all medical wastes and includes seven categories:
1. Cultures and stocks of infectious agents
2. Human pathological wastes (e.g., tissues, body parts)
3. Human blood and blood products
4. Sharps (e.g., hypodermic needles and syringes used in animal or human patient
care)
5. Certain animal wastes
6. Certain isolation wastes (e.g., waste from patients with highly communicable
diseases)
7. Unused sharps (e.g., suture needles, scalpel blades, hypodermic needles).
Etiological agents being transported interstate and samples of regulated medical waste
transported offsite by EPA or State-designated enforcement personnel for enforcement
purposes are exempt from the requirements during the enforcement proceedings.
Mixtures of solid waste and regulated medical waste are also subject to the requirements.
Mixtures of hazardous and regulated medical waste are subject to the 40 CFR Part 259
requirements only if shipment of such a mixture is not subject to hazardous waste manifesting
(e.g., the hazardous waste is shipped by a conditionally exempt generator).
Generators, transporters, and owners or operators of intermediate handing facilities or
destination facilities that transport, offer for transport, or otherwise manage regulated medical
waste generated in a Covered State must comply with the regulations even if such transport
or management occurs in a non-Covered State. Vessels at port in a Covered State are
subject to the requirements for those regulated medical wastes transported ashore in the
Covered State. The owner or operator of the vessel and the person(s) removing or accepting
waste from the vessel are considered co-generators of the waste.
A generator who treats and destroys or disposes of regulated medical waste onsite [e.g.,
incineration, burial, or sewer disposal covered by section 307(b) through (d), of the Clean
Water Act] is not subject to tracking requirements for that waste. However, such onsite waste
management may subject the generator to additional Federal, State, or local laws and
regulations.
Evaluating Compliance
The inspector should evaluate whether the generator has determined what regulated medical
waste streams are generated and/or managed. Generators of less than 50 pounds per month
are exempt from certain transportation and tracking requirements. Compliance should be
evaluated by doing the following:
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• Prior to shipping waste offsite, verify that the wastes are segregated and packed in the
appropriate containers. Verify that containers are properly marked. If containers are
reused, verify that they are decontaminated.
• Verify that the generator uses tracking forms and that copies of the forms and any
exception reports are kept for 3 years. Determine if the generator exports medical
waste for treatment, destruction, or disposal? If so, the generator must request that
the destination facility provide written confirmation that the waste was received; an
exception report must be filed if such a confirmation is not received within 45 days. If
the generator incinerates medical waste onsite, verify whether the recordkeeping and
reporting regulations for onsite incinerators are being followed.
The transportation requirements apply to transporters, including generators that transport their
own waste, and owners and operators of transfer facilities engaged in transporting regulated
medical waste generated in a Covered State. The inspector should verify that:
• The proper labeling and marking of regulated medical waste accepted for
transportation has taken place or has been done
• If the waste is handled by more than one transporter, that each transporter attaches a
water resistant identification tag below the generator's marking and that the required
information is on the tag
• The transporter submitted the required notification(s) for each Covered State
• The vehicles are fully enclosed, leakproof, maintained in sanitary condition, secured
when unattended, and marked with the proper identification
• The applicable requirements for rail shipments are followed
• Tracking forms are used properly
• Recordkeeping and reporting requirements are followed.
The requirements for treatment, destruction, and disposal facilities apply to owners and
operators of facilities that receive regulated medical waste generated in a Covered State,
including facilities located in non-Covered States. The facilities include destination facilities,
intermediate handlers, and generators that receive regulated medical waste required to be
accompanied by a tracking form. The inspector should verify the following:
• Whether tracking forms are used and have been properly completed
• Whether tracking forms discrepancies have been resolved
• Whether the recordkeeping requirements are being followed
• Whether any additional information required by the Administrator has been reported.
For rail shipments of regulated medical waste, the inspector should determine whether the
tracking forms are used properly.
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Pollution Prevention
EPA is developing an Agency-wide policy for pollution prevention. Present authorities were
established in the 1984 Hazardous and Solid Waste Amendments to RCRA (Section 3002).
The October 1990 Pollution Prevention Act established pollution prevention as a national
priority.
Evaluating Compliance
EPA has developed a policy regarding the role of inspectors in promoting waste minimization
(OSWER directory number 9938.10). As stated in the policy, to evaluate compliance, the
Inspector should:
• Check hazardous waste manifests for a correctly worded and signed waste
minimization certification.
• Determine whether this certification was manually signed by the generator or
authorized representative.
• Confirm that a waste minimization program is in place by requesting to see a written
waste minimization plan, or requesting that the plan be described orally, or requesting
that evidence of a waste minimization program be demonstrated. The inspector can,
and should, visually check for evidence of a "program in place" onsite.
• Check the Biennial Report and/or Operating record of generators and TSDFs, as
appropriate. These documents should contain descriptions of waste minimization
progress and a certification statements. If known omissions, falsifications, or
misrepresentations on any report or certification are suspected, criminal penalties may
apply and the case should be referred for criminal investigation.
• Check any waste minimization language included in the facility's permits, any
enforcement order, and settlement agreements. Verify that waste minimization
requirements are being satisfied.
The policy also states that the inspector should promote waste minimization by:
• Being familiar with, recommending, and distributing waste minimization literature.
• Referring the facility to the appropriate technical assistance program for more specific
or technical information.
• Providing limited, basic advice to the facility of obvious ways they can minimize their
waste. This advice should be issued in an informal manner with the caveat that it is
not binding in any way and is not related to regulatory compliance.
The multi-media inspection team can also document cross-media transfers of waste streams,
that can result in false claims of waste minimization. For example, a facility could treat a
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Appendix S Media-Specific Inspection Components
solvent wastewater stream in an air stripper that has no air pollution control devices. On
paper, the amount of solvent discharged to a land disposal unit or sewer system could show a
reduction, but the pollutants are going into the air, possibly without a permit. Another example
would be a facility claiming a reduction in hazardous waste generated because the waste
steam was delisted.
B. Clean Air Act (CAA)
The Clean Air Act (CAA) is the legislative basis for air pollution control regulations. It was first
enacted in 1955 and later in 1963, 1965, 1970, 1977, and 1990. The 1955 and the 1963
Amendments called for the abatement of air pollution through voluntary measures. The 1965
amendments gave Federal regulators the authority to establish automobile emission
standards.
Basic Program
The CAA Amendments of 1970 significantly broadened the scope of the Act, forming the basis
for Federal and State air pollution control regulations. Section 109 of the 1970 Amendments
called for the attainment of National Ambient Air Quality Standards (NAAQS, 40 CFR Part 50)
to protect public health and welfare from the known or anticipated adverse effects of six air
pollutants (as of 1990 the standards were for small particulates, sulfur dioxide, nitrogen
dioxide, carbon monoxide, ozone, and lead). The States were required to develop and submit
to EPA implementation plans that were designed to achieve the NAAQS. These State
Implementation Plans (SIPs) contained regulations that limited air emissions from stationary
and mobile sources. They were developed and submitted to EPA on a continuing basis and
became federally enforceable when approved.
Section 111 of the 1970 Amendments directed EPA to develop standards of performance for
new stationary sources. These regulations, known as New Source Performance Standards
(NSPS, 40 CFR Part 60), limited air emissions from subject new sources. The standards are
pollutant and source specific.
Section 112 of the 1970 amendments directed EPA to develop standards for hazardous air
pollutants. These regulations, known as the National Emission Standards for Hazardous Air
Pollutants (NESHAPs, 40 CFR Part 61), limited hazardous air emissions from both new and
existing sources.
The CAA Amendments of 1977 addressed the failure of the 1970 amendments to achieve the
NAAQS by requiring permits for major new sources. The permit requirements were based on
whether the source was located in an area that did not meet the NAAQS (non-attainment
areas). The permit program for sources in attainment areas was referred to as the Prevention
of Significant Deterioration (PSD) program.
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The CAA Amendments of 1990 significantly expanded the scope of the Act. Section 112
amendments have amended the NESHAP program with the new provisions called "Title III -
Hazardous Air Pollutants." Title III listed 189 hazardous air pollutants (Appendix O) and
required EPA to start setting standards for categories of sources that emit these pollutants
within 2 years (1992) and finish setting all standards within 10 years (2000). It also contains
provisions for a prevention-of-accidental-releases program.
Section 211 of the CAA regulates any fuel or fuel additive for use in motor vehicles if the
resulting emission would cause or contribute to air pollution that may reasonably be
anticipated to endanger public health or welfare, or if the emission products would significantly
impair any emission control device or system in general use. There are several provisions
under CAA section 211 which regulate fuels such as gasoline, diesel fuel, and fuel additives.
The Federal tampering prohibition is contained in Section 203(a)(3) of the CAA, 42 U.S.C.
7522(a)(3). Section 203(a)(3)(A) of the Act prohibits any person from removing or rendering
inoperative any emission control device or element of design installed on or in a motor vehicle
or motor vehicle engine prior to its sale and delivery to an ultimate purchaser. Section
203(a)(3)(A) also prohibits any person from knowingly removing or rendering inoperative any
such device or element of design after such sale and delivery and the causing thereof.
Section 203(a)(3)(B) of the Act prohibits any person from manufacturing, selling, offering for
sale, or installing any part or component intended for use with, or as part of, any motor vehicle
or motor vehicle engine where a principal effect of the part or component is to bypass, defeat,
or render inoperative any device or element of design installed on or in a motor vehicle or
motor vehicle engine in compliance with regulations under this title, and where the person
knows or should know that such part or component is being offered for sale or is being
installed for such use.
Section 609 of the CAA Amendments of 1990 requires facilities that perform service on
vehicle air conditioners to have recycling or recovery equipment and the technicians who use
the equipment to be certified by an EPA-approved §609 program.
Evaluating Compliance
The following procedures are used to evaluate compliance with the Clean Air Act.
Before an onsite inspection, the documents listed below should be obtained from State or EPA
files and reviewed to determine what regulations apply and what compliance problems may
exist.
• The State air pollution control regulations contained in the SIP (State regulations and
permits form the basis for the air compliance inspection and will vary from State to
State).
• The State operating and construction permits.
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• The most current emissions inventory (check for sources subject to SIP, NSPS, and
NESHAPs requirements).
• The Volatile Organic Compound (VOC) emissions inventory. (The VOC inventory may
not be included in the emissions inventory, but reported separately under SARA Title III
Form R submittal. More information on the former submittal is found in the Emergency
Planning and Community Right-to-Know section.).
• The consent decrees/orders/agreements still in effect and related correspondence.
• The most recent inspection reports.
• The most recent monthly or quarterly Continuous Emission Monitoring/Continuous
Opacity Monitoring (CEM/COM) reports.
• AIRS Facility Subsystem (AFS) reports.
• Process descriptions, flow diagrams, and control equipment for air emission sources.
• Facility plot plan that identifies and locates the air pollution emission points.
The onsite inspection should include a review of the records and documents listed below:
• Process operating and monitoring records to determine if permit requirements are
being followed.
• Fuel analysis reports (including fuel sampling and analysis methods) to determine if
sulfur dioxide emission limits and/or other fuel requirements are being met.
• Reports of process/control equipment malfunctions causing reportable excess
emissions (refer to SIP to determine reportable malfunctions and report requirements).
• Source test reports to determine if NSPS, NESHAPs, and/or major sources have
demonstrated compliance with emission standards.
• CEM reports to determine if NSPS and SIP reporting requirements are being met
(reported emissions should be checked against raw data for accuracy, and reported
corrective actions should be checked for implementation).
• CEMS/COMS certification tests (relative accuracy and calibration drift) to verify that
performance specifications at 40 CFR Part 60, Appendix B, are met.
• Records and reports specified in SIP regulations, NSPS and NESHAP subparts, and
applicable permits.
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The onsite inspection should also include the following:
• Visible Emission Observations (VEOs), by inspectors certified to read smoke within the
last 6 months, to determine compliance with SIP, NSPS, or NESHAPs opacity limits
(document non-compliance with EPA Method 9, 40 CFR Part 60, Appendix A).
• A check of real time CEM measurements to determine compliance SIP, NSPS, or
NESHAPs limits (opacity CEM measurements can be compared against VEOs).
• A review of CEM/COM calibration procedures and frequency to determine if the zero/
span check requirements and analyzer adjustment requirements of 40 CFR Part 60 are
being met.
• Observations of process and control equipment operating conditions to determine
compliance with permit conditions (if no permit conditions apply, control equipment
operating conditions can be compared to baseline conditions from stack tests or
manufacturer's specifications for proper operation).
• Observation of control equipment operating conditions and review of equipment
maintenance practices and records to determine proper operation of control equipment.
• When inspecting a fuel refinery or terminal and when time permits, the investigator
should review records to assess compliance with fuel regulations under CAA section
211. Things to look for include compliance with the new reformulated gasoline
requirements including Reid vapor pressure levels (during summer months only) and
oxygenate levels of outgoing gasoline, the sulfur content of outgoing diesel fuel, and
the lead level of unleaded gasoline leaving the refinery.
• When inspecting a facility with its own fleet of vehicles or garage, maintenance records
for the vehicles should be reviewed to determine compliance with Section 203 of the
CAA. A review of air conditioning repair/maintenance records should also be
conducted to determine compliance with Section 609 of the CAA.
• A review of all sources to determine if existing, new, modified, or reconstructed
sources have construction and operating permits required by SIP (note other process
changes that may not require a permit but could affect emissions). For example:
- Are there any boilers, stationary diesel engines (emergency generators, lift pumps),
or waste gas boilers of any size? What are their capacities, when installed or
altered?
- Are there any incinerators for sludge, grease, grit, screenings, etc.? When were
they installed or altered?
- Are there any storage tanks storing any liquid except water? What are their
capacities, when installed or altered?
- Are there any solvent or gasoline tanks? What are their capacities, when installed
or altered?
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Are there any storage silos for storing solid particles (e.g., lime)? What are their
capacities, when installed or altered?
Are there any air pollution control devices of the following types? When where they
installed or altered?
-- Odor control equipment (carbon adsorbers, scrubbers) on such equipment as
sludge handling/storage tanks, pump stations, wet-wells, metering stations, grit
screening, headworks building?
- Waste gas burners such as digester flares, boilers, etc.?
- Scrubbers on pH adjustment process or pretreatment equipment (usually HCI
control)?
Is there any shop equipment of the following types? When was it installed or
altered?
- Paint spray booths
- Shotblast booths, controlled (any size) or uncontrolled
- Solvent degreasers
Is there any wastewater or water treatment equipment designed to reduce Volatile
Organic Compounds (VOCs), which may emit air contaminants, such as aeration
basins, surface impoundments, air strippers, roughing filters, trickling filters, or
oil/water separators? When was the equipment installed or altered?
At industrial/commercial wastewater and pretreatment facilities, are there any
aeration basins, lagoons, or settling basins? When were they installed or altered?
At industrial/commercial treatment works, is there equipment used to dispense odor
reducing/masking agents? When was it installed or altered?
At industrial/commercial treatment works, is there equipment used directly to
manufacture fertilizers (including mixers, blenders, conveyors, etc.)? When was it
installed or altered?
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Appendix S Media-Specific Inspection Components
C. Safe Drinking Water Act (SDWA)
Basic Program
Public drinking water supply systems (i.e., that serve at least 25 people or have 15 service
connections) are regulated by the Safe Drinking Water Act (SDWA) Amendments of 1986.
EPA sets standards [known as Maximum Contaminant Levels (MCLs)] for the quality of water
that can be served by public water systems. Public systems must sample their water
periodically and report findings to the State (or EPA, if the State has not been delegated the
authority to enforce the SDWA). The systems must notify consumers if they do not meet the
standards or have failed to monitor or report. EPA is on a statutory schedule for promulgating
a large number of new MCLs.
The Underground Injection Control (UIC) program was developed pursuant to the SDWA
(Public Law 93-523), Part C—Protection of Underground Sources of Drinking Water (40 CFR
Parts 124 and 144 through 148). The UIC program regulates five classes of injection wells,
summarized as follows:
Class I Industrial, municipal, or hazardous waste disposal beneath the lowermost
underground source of drinking water (USDW)
Class II Oil and gas-related wells used for produced fluid disposal, enhanced recovery,
hydrocarbon storage, etc.
Class III Mineral extraction wells
Class IV Hazardous or radioactive waste disposal above or into a USDW
Class V Injection wells not included in Classes I through IV.
Evaluating Compliance
Monitoring requirements for water supply systems and whether the system can be reasonably
expected to routinely provide safe potable water should be determined. Many facilities
purchase their potable water supply from a nearby municipality. If no further treatment is
provided (e.g., chlorination by the facility), the facility remains a "consumer" rather than
becoming a "supplier," and consequently does not have the monitoring or reporting
requirements that a supplier would have. Nevertheless, the facility does have a responsibility
to ensure that their actions do not result in contamination of the municipal water supply (e.g.,
through cross-connection). The audit team should be alert to these possibilities.
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Appendix S Media-Specific Inspection Components
Inspectors should:
• Verify public water system records of monitoring and reports of exceedances of MCLs
• Interview water system personnel to identify potential operations and maintenance
problems
• Obtain water source, treatment, and service area information
• Verify that sample locations are appropriate.
For UIC inspections, the following should be reviewed:
• Current status of wells (active, abandoned, under construction repairs)
• Types of wastes discharged to wells
• Injection well construction
• Potential pathways of endangerment to Underground Sources of Drinking Water
(USDWs)
• Protection of USDWs from endangerment
• Frequency and type of Mechanical Integrity Testing (MIT)
• Annular pressure
• Annular pressure monitoring
• Radioactive tracer surveys
• Installation methods for well plugging
• Remedial operation
• Applicability of land disposal restrictions to injection well operations
• Recordkeeping and evidence documentation
• Outlets for floor drains
• Connection to "dry" wells
• Evidence of surface ponding.
Several States and industries have requested approval of alternative mechanical integrity
testing methods or variances to accommodate special local hydrogeological conditions,
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Appendix S Media-Specific Inspection Components
historical practices, or industry interests. Inspectors and field investigators should be
cautioned to keep current with special permit conditions and the status of any pending
approvals/denials of alternative mechanical integrity testing procedures and variances.
D. Toxic Substances Control Act
(TSCA)
This section describes those specific aspects of toxic substances control that are addressed
by the Toxic Substances Control Act (TSCA) and its associated rules and regulations (40 CFR
Parts 702 through 799).
Basic Program
The regulation of toxins under TSCA is divided into two components for Agency enforcement
program management purposes.
1. "Chemical control" covers enforcement aspects related to specific chemicals
regulated under Section 6 of TSCA, such as Polychlorinated Biphenyls (PCBs),
Chlorofluorocarbons (CFCs), and asbestos.
2. "Hazard evaluation" refers to the various recordkeeping, reporting, and submittal
requirements specified in Sections 5, 8, 12, and 13 of TSCA; although, some
elements of what might be termed "chemical control" are also addressed in these
sections. Sections 12 and 13 of TSCA, which pertain to chemical exports and
imports, respectively, will not be covered in this manual because of their special
nature and unique requirements.
Prior to discussing TSCA activities at a facility, the investigator must present appropriate
facility personnel with copies of two TSCA inspection forms:
1. Notice of Inspection—Shows purpose, nature, and extent of TSCA inspection.
2. TSCA Inspection Confidentiality Notice—Explains a facility's rights to claim
information at the facility as TSCA Confidential Business Information.
Before leaving the site, two additional forms must be completed, as appropriate:
1. Receipt for Samples and Documents—Itemizes all documents, photos, and samples
received by the investigator during the inspection.
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Appendix S Media-Specific Inspection Components
2. Declaration of Confidential Business Information—Itemizes the information that the
facility claims to be TSCA Confidential Business Information.
Evaluating Compliance
Chemical Control
Although the controlled substances most frequently encountered during multi-media
investigations are PCBs, the investigator should determine if other regulated toxic substances
are present at the facility. Currently these include metal working fluids (Part 747), fully
halogenated chlorofluoroalkanes (40 CFR Part 762), and asbestos (40 CFR Part 763);
additional toxic substances may be regulated in the future. Because the probability of finding
PCBs and PCB-items at the facility is greater than finding other TSCA-regulated substances,
the following discussion is directed toward an evaluation of compliance with proper PCB and
PCB-item handling procedures. If other TSCA-regulated substances are found, the
investigator should consult the regulations for appropriate requirements.
Management of PCBs/PCB-items is regulated under 40 CFR Part 761. In general, these
regulations address recordkeeping, marking and labeling, inspections, storage, and disposal.
Facilities that store and/or dispose of PCBs and PCB-items should have EPA-issued letters of
approval that contain facility operating and recordkeeping requirements in addition to those
specified in 40 CFR Part 761. The investigator must obtain a copy of these approvals and
any subsequent notifications to evaluate facility compliance. The inspector should review Part
761.30 to identify uses of PCB transformers which are prohibited beginning October 1, 1990,
but with effective dates extending to October 1, 1993. The inspector should also review the
requirements found in Part 761.30 that allow the installation of PCB transformers for
emergency use.
In general, the compliance evaluation includes obtaining and reviewing information from
Federal, State, and local regulatory agency files; interviewing facility personnel regarding
material handling activity; examining facility records and inspecting materials handling units.
Specific investigation tasks include:
• Inspect all in-service electrical equipment, known or suspected of containing PCBs, for
leaks or lack of proper marking. A similar inspection should also be made of any
equipment that the facility is storing for reuse. Make certain that any remedial actions
were quick and effective in the case of leaks, spills, etc.
• If the above equipment includes any PCB transformers or capacitors, make certain that
all relevant prohibitions are being met, such as those involving enhanced electrical
protection, as well as other requirements in the Use Authorization section of the PCB
Rule. Make certain that any hydraulic or heat transfer systems suspected of
containing PCB fluids have been properly tested.
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Appendix S Media-Specific Inspection Components
Determine whether the facility is involved with servicing PCB items or using/collecting/
producing RGBs in any manner. If so, make certain that the appropriate requirements
of the PCB Rule are being met.
Determine whether the facility is involved with either the storage or disposal of PCBs/
PCB-items. Inspect all storage for disposal facilities for proper containment, leaking
items, proper marking, dates/time limits, location, protection from elements, and other
necessary requirements. If the facility disposes of PCBs, make certain that proper
methods are being employed and that design and operation of disposal units is in
accordance with regulatory requirements.
Determine whether storage/disposal facilities are complying with the notification and
manifesting requirements contained in Subpart K of the PCB Rule.
Thoroughly review, for purposes of adequacy and regulatory compliance, all records
and reports required by the PCB Rule including the following:
- Annual documents
- Inspection logs
- PCB transformer registration letters
- Manifests/certificates of destruction
- Test data
- Spill cleanup reports
- EPA-issued permits or letters of approval
- SPCC plan, if one is necessary
- Operating records
- Notification of PCB activity.
Hazard Evaluation
Establishing compliance with the various hazard evaluation aspects of TSCA is best
accomplished through review and evaluation of the recordkeeping, reporting, and submittal
data required by the various regulatory components of Sections 5 and 8. In general, Section
5 addresses new chemicals (i.e., those not on the TSCA Chemical Substances Inventory) and
Section 8 addresses existing chemicals (i.e., those chemicals that are on the TSCA Chemical
Substances Inventory).
Much of the information obtained and reviewed under these two sections of TSCA will be
declared "TSCA Confidential Business Information" by company official, and thus special
security procedures must be followed during review and storage of the documents.
40 CFR Parts 703 through 723 should be consulted for an explanation of TSCA terms and
definitions. The following list summarizes the different objectives for inspections of the key
TSCA Sections 5 and 8 components.
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Appendix S Media-Specific Inspection Components
1. Premanufacture Notification (PMN)
a. Verify that all commercially manufactured or imported chemicals are on the TSCA
Chemical Substances Inventory, are covered by an exemption, or are not subject to
TSCA.
b. Verify that commercial manufacture or import of new chemicals did not begin prior
to the end of the 90-day review date, and not more than 30 days before the Notice
of Commencement (NOG) date. If commercial manufacture or import has not
begun, verify that no NOC has been submitted.
c. Verify the accuracy and documentation of the contents of the PMN itself.
2. Research and Development (R&D) Exemption
a. Verify that the recordkeeping and notification requirements are being met for all
R&D chemicals.
b. Verify that "Prudent Laboratory Practices" and hazardous data searches are
adequately documented.
3. Test Marketing Exemption (TME)
a. Verify that the conditions spelled out in the TME application are being met,
particularly with respect to dates of production, quantity manufactured or imported,
number of customers and use(s).
b. Verify that the TME recordkeeping requirements are being met.
4. Low Volume Exemption (LVE) and Polymer Exemption (PE)
a. Verify that specific conditions of the exemption application are being met, and that
all test data have been submitted.
b. For an LVE, verify that the 1,000-kg limit per 12-month period has not been
exceeded. For a PE, ensure that the chemical structure and monomer
composition(s) are accurate.
c. Verify that recordkeeping requirements for both LVEs and PEs are being met.
5. 5(e)/5(f) Order, Rule, or Injunction
a. Verify that all conditions of the order, rule, or injunction are being followed, including
use of protective equipment, glove testing, training, and recordkeeping.
b. If a testing trigger is specified, verify production volume and status of testing
activity.
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Appendix S Media-Specific Inspection Components
6. Significant New Use Rule (SNUFO
a. Verify that no commercial production has occurred prior to the 90-day review date.
b. Verify that SNUR notices (i.e., Significant New Use Notices [SNUNs] have been
submitted for all applicable manufactured, imported, or processed chemicals.
c. Verify technical accuracy of SNUN and completeness of required recordkeeping.
7. Bona Fide Submittals
Determine the commercial production (or import) status and R&D history of those bona
fide chemicals not found on the confidential 8(b) inventory. Verify findings against
applicable PMN, TME, and other exemption.
8. Section 8(a) Level A PAIR and CAIR Report
a. Determine if Preliminary Assessment Information Rule (PAIR) and Comprehensive
Assessment Information Rule (CAIR) reports have been submitted for all 8(a) Level
A listed chemicals manufactured or imported by the facility.
b. Verify the accuracy of submitted PAIR information, particularly the reported figures
for total production volume and worker exposure levels.
c. Verify the accuracy of submitted CAIR information and if the report meets the date
specified in the regulation.
9. Section 8(b) Inventory Update Rule (IUR)
a. Verify the accuracy of the information submitted in response to the IUR.
b. Determine that required information was submitted by the deadline for all chemicals
subject to IUR.
10. Section 8(c) Recordkeeping
a. Determine if the facility has a Section 8(c) file and that allegations of significant
health and environmental harm on record are properly filed and recorded.
b. Determine that all applicable allegations have been recorded and filed.
c. Determine if the facility has a written Section 8(c) policy and if the policy includes
outreach to the employees.
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Appendix S Media-Specific Inspection Components
11. Section 8(d) Reporting
Determine if copies (or lists) of all unpublished health effects studies have been
submitted by manufacturers, importers, and processors for any Section 8(d) listed
chemical.
12. Section 8(e) Reporting
a. Verify that all Section 8(e) substantial risk reports to the Agency were accurate and
submitted within the required time frames.
b. Verify that all substantial risk incidents and/or test results have been reported to
EPA.
c. Determine that the company has an adequate written policy addressing Section
8(e), and that it relieves employees of individual liability.
E. Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA)
Basic Program
Pesticides are regulated by FIFRA and regulations promulgated pursuant to FIFRA. Many
States have primary enforcement responsibility for FIFRA. Under FIFRA, pesticide products
must be registered by EPA before they are sold or distributed in commerce. EPA registers
pesticides on the basis of data adequate to show that, when used according to label
directions, they will not cause unreasonable adverse effects on human health or the
environment.
To ensure that previously registered pesticides meet current scientific and regulatory
standards, in 1972 Congress amended FIFRA to require the "reregistration" of all existing
pesticides.
Evaluating Compliance
The following list is used in conjunction with specific storage/use/disposal requirements found
on pesticide labels. FIFRA requires a written Notice of Inspection and written Receipt for
Samples collected.
• Determine types and registration status of all pesticides produced, sold, stored, and
used at the facility, particularly if any are restricted or experimental use pesticides.
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Appendix S Media-Specific Inspection Components
• Determine use(s) of each pesticide.
• Determine certification status of facility/handlers.
- Verify who certifies facility/pesticide handlers (EPA, State, Department of Defense).
- Determine if commercial or private application.
- If restricted-use pesticides are used, check if pesticide applicators are authorized to
use these pesticides.
- Check expiration dates on licenses/certificates.
• Review applicable records.
- Check previous inspection records and complaints.
- Check application records.
- Check restricted-use pesticides records (must be kept at least 2 years). Document
suspected violations accordingly.
- Check inventory records.
- Check training records.
- Check equipment repair records.
• Inspect storage, mixing/loading, and container disposal areas
- Check bulk storage areas for compliance with Federal/State rules.
- Check location, ventilation, segregation, shelter, and housekeeping of pesticide
storage handling areas. Check security, fire protection, and warning signs, as may
be required by State regulations.
- Check mixing equipment/procedures for reducing handlers' exposures to pesticides.
- Check for safety equipment/procedures/use.
- Check container cleanup and disposal procedures.
• Pesticide waste disposal
- Check to see that pesticides are disposed of in accordance with applicable label
and RCRA requirements.
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Appendix S Media-Specific Inspection Components
• Determine measures taken to ensure worker safety.
- Check pesticide use records for re-entry time limit notation.
- Check pesticide use records for informing farmer(s) or warning workers and/or
posting fields.
• Observe actual pesticide application.
- Observe mixing/loading and check calculations for proper use dilution.
- Observe when spray is turned on/off with respect to ends of field.
- Watch for drift or pesticide mist dispersal pattern.
- Note direction of spraying pattern and trimming techniques.
- Record wind speed and direction, air temperature, and relative humidity.
- Observe application with respect to field workers, houses, cars, power lines, and
other obstacles.
- Determine if applicator and assisting personnel are wearing safety gear required by
the label.
F. Emergency Planning and
Community Right-to-Know Act
(EPCRA)
Basic Program
(f
The Emergency Planning and Community Right-To-Know Act of 1986 is a free-standing law
contained within the Superfund Amendments and Reauthorization Act (SARA) of 1986.
EPCRA is also commonly known as SARA Title III. EPCRA requires dissemination of
information to State and community groups and health professionals on chemicals handled at
regulated facilities.
An EPCRA inspection verifies that the facility owner/operator has notified State and local
agencies of regulated activities; has submitted information to specific State and local
agencies; and has prepared and submitted all other required reports.
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Appendix S Media-Specific Inspection Components
Evaluating Compliance
Emergency Planning (Sections 301 through 303)
EPA promulgated regulations that identify extremely hazardous substances and the levels to
be regulated under EPCRA. The inspector should determine whether the facility is subject to
EPCRA regulation. If the facility does meet the requirements, the inspector should verify
whether the facility owner/operator:
• Notified the State emergency response agency and the local emergency planning
committee that the facility is regulated under EPCRA.
• Designated a facility emergency coordinator to assist the local emergency planning
committee in the planning process.
• Notified the local emergency planning committee of the emergency coordinator's
identity.
Emergency Notification (Section 304)
The owner/operator of a facility subject to EPCRA must immediately report releases of
hazardous substances. Substances subject to this requirement are the extremely hazardous
substances listed in 40 CFR Part 355 and substances subject to the emergency notification
requirements under CERCLA Section 103(a) or (c). The inspector should verify whether an
immediate notification was made to the:
• State emergency response commission
• Local emergency planning committee
• National Response Center for spills involving CERCLA reportable quantities.
Community Right-to-Know Requirements (Sections 311 through 312)
Manufacturing facilities subject to the Occupational Safety and Health Act (OSHA) Hazardous
Communication regulation (29 CFR Part 1910) are required to prepare Material Safety Data
Sheets (MSDS) for each hazardous chemical handled at the facility. Manufacturing facilities
contained within Standard Industrial Classification (SIC) Codes 20 through 39 are subject to
these requirements. OSHA revised its Hazardous Communication Regulation, effective
September 23, 1987, to require that MSDSs be prepared by nonmanufacturing facilities. The
inspector should verify that the facility owner/operator has sent the following to the State
emergency response commission, the local emergency planning committee, and the local fire
department:
• MSDSs or a list of chemicals covered by MSDSs found at the facility
• An annual inventory of hazardous chemicals found at the facility.
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Appendix S Media-Specific Inspection Components
Toxic Chemical Release Reporting (Section 313)
Covered facilities (40 CFR 372.22) that manufacture, import, process, or use certain
chemicals above specified amounts must annually report releases to the environment. The
inspector should determine whether the facility owner/operator is required to submit this
annual report (Form R). The following criteria are applied to determine if the facility is
required to report:
• The facility has the equivalent of 10 or more full-time employees.
• The facility conducts general manufacturing activities that fall within SIC Codes 20-39.
• The facility manufactured on processed in excess of 25,000 pounds or used in any
other manner 10,000 pounds or more of the chemicals listed on the Toxic Release
Inventory (TRI).
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APPENDIX T
NATIONAL MULTI-MEDIA SCREENING
INSPECTION CHECKLIST
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Appendix T National Multi-Media Screening Inspection Checklist
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MEMORANDUM OFFICE OF ENFORCEMENT
SUBJECT: National Multi-Media Screening Inspection Checklist Used as a Guideline
FROM: Steven A. Herman
Assistant Administrator
TO: Regional Administrators
Headquarters Compliance Program Directors
Thank you for your comments on the proposed National Multi-Media Screening
Inspection Checklist (3/29/93), developed by the Environmental Services Divisions (ESDs),
and led by Region III under the auspices of the Enforcement Management Council (EMC).
The national checklist consolidated the best of the existing screening questions into one
guideline as requested by the EMC. This was a useful project and I commend it.
This memorandum responds to four key issues raised in your comments: 1) the use of
the national checklist as a model or guideline; 2) the amount of flexibility that Regions will
have to implement screening; 3) the use of multi-media screening in all single media
inspections versus targeted use of screening; and 4) time to complete screening relative to the
amount of time required for completion of routine single media inspections. The approach,
recommended both by my office and Greene Jones (ESD Director, Region III) who organized
the national checklist project, was discussed and endorsed by the EMC on April 28, 1993.
Use of the National Multi-Media Screening Inspections Checklist As a General Guideline in FY
1993
The majority of Regions have developed and are using regional checklists. These
Regions should review the attached national checklist and make further modifications of their
checklists as they see fit. Any Region that was not using a screening inspection checklist in
FY 1993 should adopt the national checklist as is or modify it to address regional needs. In
either case, multi-media screening should continue during this fiscal year. Region III has
reviewed the comments on the checklist and made minor modifications to that portion where
there was a consensus concerning the RCRA Program. The revised national checklist is
attached (dated 5/12/93).
Frequency of Use of Screening
The goal in FY 1993 has been to use multi-media screening in all single media
inspections at facilities with potential multi-media impacts. Regions have adopted different
approaches to the use of screening, but all those who commented prefer a targeted use of
multi-media screening inspections at this time. I recognize that multi-media screening may not
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Appendix T National Multi-Media Screening Inspection Checklist
be productive or beneficial at some facilities. However, I believe that at the majority of
facilities screening will be useful, and I encourage you to incorporate multi-media screening
inspections in as many single-media inspections as possible.
Creation of a Multi-Media Screening Inspection Work Group
To answer the many questions that still remain about the best approaches to realizing
the benefits of multimedia screening inspections, the EMC agreed that OE should work with
the Regions and Headquarters to share and to evaluate current practices. We agreed that OE
will create a screening inspection work group, reporting to the EMC, with representatives of
Headquarters' and Regions' Compliance Programs, the Regional Counsels, the National
Enforcement Investigations Center (NEIC), and the ESDs, but OE will keep this group as
small as possible.
The work group will build upon the ESDs' effort and focus on the key issues raised in
your comments. This will include sharing approaches to the following: managing and
organizing multi-media screening inspections; making use of screening-level information; and
evaluating the results and benefits of screening inspections. The group will also explore the
need, if any, for national consistency in multi-media screening inspections while preserving
regional flexibility. Regions will be asked to assess their multi-media screening inspection
programs for the fiscal year in a manner that will be defined by the work group. OE will
provide further details on this new project in a separate memorandum.
If you have any questions, please contact Cheryl Wasserman, Chief, Compliance
Policy and Planning Branch or Becky Barclay, Program Analyst on (202) 260-7550.
Attachment: National Multi-Media Screening Inspection Guidance and Checklist
(5/12/93)
cc:
Deputy Regional Administrators
Regional Counsels
Regional Division Directors
OE Office Directors
OE Enforcement Counsels
OCAPO Managers
Enforcement Management Council
Steering Committee on the State/Federal Enforcement Relationship
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Appendix T National Multi-Media Screening Inspection Checklist
MULTI-MEDIA SCREENING INSPECTION PROGRAM GUIDANCE
AND NATIONAL CHECKLIST
(5/12/93)
I. PROGRAM OBJECTIVES
Greater use of multi-media field screening means that EPA is bringing a multi-media
outlook into the enforcement process at an earlier stage, rather than at the later stages of
case development or settlement. By having multi-media screening information earlier, in the
process, EPA Regions can do the following: 1) better target resources for coordinated or
consolidated inspections; 2) improve the planning for and coordination of single and multi-
media cases; and 3) better assure that all significant releases to the environment are included
in any facility-specific enforcement strategy.
The specific objectives of a multi-media screening inspection program are to identify
the more obvious unpermitted activities and any other readily detectible instances of non-
compliance by using indicators of non-compliance in environmental programs, beyond the
primary objective of a single program inspection. Information obtained should be preserved
as a whole and also should be referred to a compliance program office(s) or the State, as
appropriate. Follow up action could include a coordinated or consolidated inspection (full
inspections for one or more programs), or in some instances, an immediate enforcement
action.
As a guide for making and recording observations and pertinent information, the
compliance inspector will use a multi-media screening checklist. Examples of observations of
potential compliance issues include the following: inoperable control systems; unusual
emissions or discharge; evidence of spills or leaks; breached dikes, new emissions or
discharges sources; lack of permits or Spill Prevention, Containment and Control (SPCC)
Plan; abandoned drums; etc.
II. NATIONAL MULTI-MEDIA SCREENING INSPECTION CHECKLIST AS A GENERAL
GUIDELINE IN FY 1993
The Environmental Services Divisions' Field Branch Chiefs and the National
Enforcement Investigations Center (NEIC) have led the development and implementation of
EPA's multi-media inspection program, including screening inspections. The attached
National Multi-Media Screening Inspection Checklist (5/12/3) was developed as a general
guideline by a regional work group led by Region III. Region III collected eight existing
Regional checklists and analyzed the programs and types of questions contained in these.
From this analysis, Region III compiled a national checklist that serves the following
purpose: 1) to detect unpermitted discharges, emissions or sources; 2) to gather information
on suspected violations of existing regulations or permits across media at a facility or site; and
3) to identify other potentially significant environmental problems which may lie outside EPA's
specific statutory mandates but that may warrant some type of follow up.
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Appendix T National Multi-Media Screening Inspection Checklist
The national checklist is very broad in scope, covering eleven (11) programs with
about seventy (70) questions. To answer these questions, about 45% require field
observation and 55% require interview or file review. (See Table 1. Existing Regional Multi-
Media Screening Checklists for a summary of programs covered by each Regional checklist.)
The national checklist also includes a section, "Environmental Assessment", to identify other
potentially significant environmental problems which may warrant some type of follow up.
Given this breadth, the work group that developed the checklist estimates that one (1) work
day would be required to complete the national checklist in its present form at most facilities.
The majority of Regions have developed and are using regional checklists. These
Regions should review the attached national checklist (5/12/93) and make further
modifications of their checklists as appropriate. Any Region that was not using a screening
inspection checklist in FY 1993 should adopt the national checklist as is or modify it to
address regional needs. In either case, multi-media screening should continue during this
fiscal year using the national checklist as a general guideline.
Each Region should review the effectiveness of the multi-media screening inspection
program once per year. This Review should consider factors such as the compliance issues
discovered; success as a targeting tool; value of negative findings (e.g. no planning and
development, etc). OE will work with the Regions and Headquarters to review their multi-
media screening inspection programs by forming a multi-media screening inspection work
group, reporting to the Enforcement Management Council.
III. IMPLEMENTATION OF MULTI-MEDIA SCREENING INSPECTIONS
1. FY 1993 Goal for Use of Multi-Media Screening Inspections Checklist/STARS
Credit
As part of the overall effort to incorporate a multi-media perspective into all of EPA's
enforcement activities, the Deputy Administrator requested that all single media inspections
use a multi-media screening checklist during FY 1993. This goal was articulated in the
"Overview" to the FY 1993 Operating Year Guidance (USEPA, 7/92).
Regions have adopted different approaches to the use of screening inspections and
prefer a targeted use of these inspections at this time. OE recognizes that multi-media
screening may not be productive or beneficial at some facilities, but that it may be useful at
the majority or facilities. Therefore, OE encourages that multi-media screening be
incorporated into as many single media inspections as possible.
To give recognition to multi-media screening, OE modified the Strategic Targeted
Activities for Results Systems (STARS) for FY 1993 to include a measure for reporting the
number of single media inspections with multi-media screening. Regional reporting will occur
as planned in the third and fourth quarters of FY 1993 and in FY 1994.
2. Training in How to Use the National Checklist
Formal classroom training in how and why to use the national checklist and a multi-
media screening inspection training manual (5-10 pages) will be available in FY 1994. The
National Enforcement Investigations Center (NEIC), the ESDs and the National Enforcement
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Appendix T National Multi-Media Screening Inspection Checklist
Training Institute (NETI) together will develop the necessary training materials for the
checklist. Each Region can modify these materials to conform with the use of the checklist in
that Region.
3. Pre-1 nspection Preparation
Because of the breadth of the multi-media screening inspections guided by the national
checklist, some pre-inspection preparation and use of existing information is highly desirable.
However, the extent to which this can be done depends on the structure and location of
Regional program files and records; the availability of information collection support for
inspectors; and access to Integrated Data for Enforcement Analysis (IDEA). Each Region
should review its regional checklist [national checklist] and identify existing sources of
information for an inspector to easily access and use to complete portions of the checklist
during pre-inspection preparation. Each checklist, regional or national, could be modified to
denote (with an asterisk) those questions on the checklist for which EPA may already have
information.
a. Focus on Questions to Answer in the Field
Depending on the facility or source, EPA compliance inspectors can anticipate answers
to some questions, particularly those that require file reviews for the answers, by gathering the
information from existing EPA files and databases where these are readily available.
Requesting an IDEA report from the respective regional contact (or having direct access) as a
routine part of pre-inspection preparation may also be valuable. Having this information prior
to the inspection will allow the inspector to focus multi-media screening on changes to a
facility's status or condition which are subjects that can only be determined on site.
b. Use of Screening Inspections at a Facility or Site More than Once Per Year
If during the course of the year, multiple single-media inspections are planned at a
given facility or site, the compliance inspector should ascertain whether a completed multi-
media screening inspection checklist already exists in EPA's records for the facility. If yes,
then the screening inspection could focus, as appropriate, on identifying changes from the
status or conditions of the facility that were recorded on a multi-media screening inspection
checklist during a prior single media inspection.
3. Access to and Referral or Data in Completed Checklists
To get the greatest value from the completed checklist, each Region must ensure that
a process exists for referring data on suspected violations or unpermitted discharges,
emissions, or activities to the relevant programs(s). Each Region should also ensure that
completed checklists are preserved as a whole, and that EPA compliance inspectors and
other EPA personnel have easy access to completed checklists by establishing relevant filing
or record keeping systems and procedures, manual or electronic. The referral process should
include formal written procedures both for the inspector to refer potential compliance issues to
the appropriate program and for the program to report back to the inspector. This should
include a system for sharing completed checklists with States and referring matters to them as
appropriate.
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Appendix T National Multi-Media Screening Inspection Checklist
4. States Use of the National Multi-Media Screening Inspection Checklist
As part of the Addendum on Multi-Media Enforcement (5/92), EPA agreed to share
methods and materials with States to advance multi-media enforcement. Each Region should
share this national checklist with the multi-media enforcement contact or coordinator
designated by each State; however, use of these materials by a State is optional.
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Appendix T National Multi-Media Screening Inspection Checklist
MODEL MULTI-MEDIA SCREENING CHECKLIST
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Appendix T National Multi-Media Screening Inspection Checklist
GENERAL INFORMATION
1. Inspector(s) Name 2. Date
3. Facility Name/Address
4. Facility Contact(s)/Title(s)
5. Description of Facility Operations
SIC Code
Number of Employees
Operating Schedule
Major Products/Production Capacity
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Appendix T National Multi-Media Screening Inspection Checklist
RCRA
Observations
1. Does the facility generate anything that looks like waste material that might contain
hazardous constituents?
2. If so, describe what the facility says regarding the RCRA regulatory status of the waste
material and their rational for such determination, (e.g., have they made a RCRA waste
identification and what was that determination? Have they determined the waste to be exempt
from regulation and why?
3. Describe the process that generates the waste material.
4. Do you see any containers of hazardous waste, land disposal units, lagoons, treatment
units? Approximately how many?
5. Were any of the units that contain or handle hazardous wastes (containers, berms, dikes,
tanks, piping, impoundments, etc.) in poor condition, unmarked, opened, leaking, cracked,
corroded, or in a condition that would allow the release or potential release of hazardous
wastes? If yes, describe unit(s). Any actual or evidence of past releases observed? If so,
describe waste (i.e., liquid, sludge, etc.) unit(s), and location.
6. Does the facility operate a boiler or industrial furnace which burns hazardous wastes?
Was there any incineration of hazardous waste on site?
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Appendix T National Multi-Media Screening Inspection Checklist
7. Was there any evidence of spills, leaks, or discharges of hazardous wastes? If so,
provide location and description.
Interview Questions/Records Review
1. If the facility is a generator of hazardous waste was there a notification of hazardous
waste activity? What is the quantity (kilograms/month) of hazardous wastes produced? How
are they produced?
2. What is the EPA Identification Number?
3. What was the basis (i.e. test, knowledge of process and waste) for determining if the
facility did or did not produce or handle hazardous wastes? Who made the determination?
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Appendix T National Multi-Media Screening Inspection Checklist
UST
Observations
1. Are there any underground storage tanks?
2. Approximately how many? What are the contents? (Wastes, virgin petroleum, or
chemicals)
3. What type of leak detection is used? When was it last used?
4. Is there any evidence of leaks, spills, broken piping, broken fill/vent lines, or leaking pump
joints or valves? Provide location and description.
Interview Questions/Records Review
1. If the tanks are for virgin petroleum or chemicals (not wastes), are they registered with
the state? Date of registration? Date of tank(s) installation?
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Appendix T National Multi-Media Screening Inspection Checklist
SPCC
Observations
1. Does the facility have the capacity to store oil either in above or below ground tanks?
How many gallons? Does any tank have a capacity of more than 660 gallons in a single tank
or does the facility have a capacity of more than 1320 gallons in a number of tanks or a
capacity of more than 42,000 gallons below the ground?
2. What type of secondary containment is used at the facility? Were there any deficiencies
in the secondary containment (cracks, broken, dikes left open)? Is it adequate to contain the
entire contents of the largest tank?
Interview Questions/Records Review
1. Does the facility have a certified (signed by a P.E.) plan? When was it last updated?
2. Has there been any major changes to oil storage at the facility since the last modification
of the plan?
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Appendix T National Multi-Media Screening Inspection Checklist
WETLANDS
Observations
1. Are there any wet areas near the facility with wetland-type vegetation (cattails, rushes,
sedges) that have been disturbed by waste disposal, ditching, or filling?
Interview Questions/Records Review
1. Does the facility have a federal section 404 permit or any state or local permit authorizing
the fill?
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Appendix T National Multi-Media Screening Inspection Checklist
FIFRA
Observations
1. Does the facility produce pesticides?
2. Is the facility applying pesticides?
3. Where are the pesticides stored?
Interview Questions/Records Review
1. If the facility produces pesticides what is the establishment's registration number?
2. If the facility is applying pesticides what is the registration number of the pesticides?
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Appendix T National Multi-Media Screening Inspection Checklist
AIR
Observations
11 ™— H
1. Is there any asbestos on site?
2. Is the facility undergoing or has the facility undergone any renovations or demolitions
during the last 18 months which involve the removal or disturbance of asbestos-containing
materials? Approximately how much asbestos (square feet or linear feet) was removed?
3. Does the facility have any coating or printing operations? Does the facility use any paints
or organic solvents? What, if any, type of air pollution control is used? Was it operating?
4. Were there any odors? What process was the source of the odors? Describe the odors.
5. Were there any visible (opaque smoke) emissions? What process was the source?
Were their any fugitive (not from a stack) emissions? Was the air pollution control equipment,
if any, operating? Describe source.
Interview Questions/Records Review
1. If asbestos was removed was notification provide to the State and EPA?
2. If the facility has coating or printing operations are they water based or organic solvent
based?
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Appendix T National Multi-Media Screening Inspection Checklist
3. Does the facility handle/emit any of the National Emission Standards for Hazardous Air
Pollutants (NESHAP) chemicals other than asbestos (mercury, beryllium, vinyl chloride,
benzene, arsenic, radionuclides)? Describe process.
4. Has the facility added new or expanded existing processes in the last two years? Was it
permitted by EPA of the State?
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Appendix T National Multi-Media Screening Inspection Checklist
TSCA-PCB'S
Observations
1. Did the facility have or does it have any PCB electrical equipment? What equipment
(type and quantity) is on-site?
2. Does the facility have a PCB equipment storage area for disposal or reuse? Describe
the storage area (i.e. concrete pad, walls, roof, curbs).
3. Are there any labels/markings on the PCB equipment?
4. Is there any leaking PCB electrical equipment? Describe.
5. Does the facility have any hydraulic systems? Any leaking?
Interview Questions/Records Review
1. If the facility has PCB electrical equipment was it tested? What were the test results?
2. If the facility has any hydraulic systems when were they tested for PCBs? What were the
test results?
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Appendix T National Multi-Media Screening Inspection Checklist
WATER-NPDES
Observations
1. Does the facility use water in it's manufacturing process?
2. Does the facility discharge to a stream, municipal sewer, or use subsurface disposal?
3. What process(es) generate wastewater? Is the wastewater treated? Is the effluent
clear? Does the treatment plant appear to be maintained (look for rust, dry basins,
abandoned equipment, etc.)?
4. Where does the storm water drain to?
5. Where do floor drains discharge?
Interview Questions/Records Review
1. How is the treatment plant's sludge disposed? How is it tested?
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Appendix T National Multi-Media Screening Inspection Checklist
EPCRA
Interview Questions/Records Review
1. Were there any chemical releases in excess of the reportable Superfund quantities (see
below)? Who was provided the notification? Was it oral or written?
2. Does the facility manufacture, process, or use any toxic chemicals in a quantity greater
than 10,000 Ibs/yr? Identity them. Are any of them section 313 chemicals (see below)?
3. If the answer to question 2 is yes, has the facility submitted the toxic chemical release
form (R)?
4. Does the facility have the Material Safety Data Sheets on site and were they submitted to
the State Emergency Response Commission (SERC) and/or the Local Emergency Planning
Committee (LEPC)?
5. Has the facility submitted the Emergency and Hazardous Chemical Inventory forms to the
LEPC and SERC?
The chemicals subject to these requirements can be found in EPA publication number 560/4-92-
011, January 1992, "Title III, List of Lists". T-19
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Appendix T National Multi-Media Screening Inspection Checklist
SDWA-UIC
Observations
1. Are there any discharges other than sanitary waste (i.e. industrial wastes) into or onto
(including drain fields) the ground? Is an on-site septic disposal system used? Describe the
discharges and disposal system.
Interview Questions/Records Review
1. Does the facility have or has it had any wells (dug, drilled or driven), dry wells,
leachfields, or septic systems? Did they receive(d) commercial or industrial waste (liquid
and/or solid), cooling water, or drainage from roof drains, floor drains, or parking lots? If yes,
give a description.
2. Does the facility have a permit?
3. What is the current status of wells (active, abandoned, under construction, repairs)?
4. If the wells are inactive what was the date they were last used?
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Appendix T National Multi-Media Screening Inspection Checklist
SDWA-PWS
Interview Questions/Records Review
1. What is the facility's source of drinking water? Does the facility have a private well?
How many people does it serve?
2. Is the water sampled and analyzed for contaminants? Are the results reported to the
state or EPA?
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Appendix T National Multi-Media Screening Inspection Checklist
ENVIRONMENTAL ASSESSMENT
1. Is there any evidence of environmental impacts that haven't been addressed? Possible
examples include:
- additional evidence of spills, leaks
- vegetation damage in the surrounding area
- odors in the surrounding neighborhood
- neighborhood covered with "dusts"
- poor water quality in streams near the facility
2. Were there situations of possible excessive occupational exposure that should be
referred to OSHA?
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•it U.S. GOVERNMENT PRINTING OFFICE: 1995 624-402-82343
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