NPDES
COMPLIANCE EVALUATION
INSPECTION
MANUAL
OFFICE OF ENFORCEMENT
OFFICE OF WATER ENFORCEMEN
COMPLIANCE BRANCH
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FO REWARD
Inspection, activities conducted by EPA and States in suitor" o1
NPDES program constitute a significant component of Lhe overai] wat-?/
enforcement program. In Fiscal Year 1976, EPA and Stales condurr.eu
5,500 sampling and 19,000 non-sampling inspections of mrrjor municipal
and non-municipal dischargers. A program of thJ s si'/.c, being condu-., ced by
a number of organizations necessitates a consi st^n-*: pr.nner of performing
inspections and a uniform inspection reporting format.. The Compliance
Evaluation Inspection Manual fulfills a portion oC chis need in i.he area
of inspections where samples are not collected. i'he Manual it, no rerve
as guidance for the field staff in the conduct of NPDES inspect! or
activities. A companion Manual dealing with sampling considerations tor
Compliance Monitoring is presently under development.
In reading the Manual you will note that a Compliance Evaluation
Inspection is not a "walk through" or "casual" typp of inspection. The
Manual describes procedures for a thorough inspection of a permit c,-v 's
facility designed to verify that the permittee is mer-tinq pernit require-
ments for records maintenance, operation and maintenance, corr>i i.-ux-e
schedule, self monitoring, and reporting. Special emphasis is placed on
assuring that the permittee is collecting representative samples of" his
discharge and that the samples are analyzed using proper lahornr.orv
techniques and approved methods. This emphasis pl'icea on g pent:
self -monitor ing procedures should result in an improvement in t*
quality of self -monitor ing data.
Finally, consistent reporting of inspection resuu t.s is ess^
for assessment of program progress. Chapter IX of the Manua i co'icai ns
the procedure to be used by the inspector in romp1 ol. i»~iy th^ f\>mpiian~e
Evaluation Inspection Report Form. The Form is c. r^visiun of i:he
On Operation And Maintenance Of Wastewater Treatment Plant t'KP/- ^'cTuin
7500-5) which deletes data elements formerly required Jri an O&"'> inspec-
tion and adds data elements necessary for assessment of the compliance
status of the facility.
The objective of this Manual is to improve., trie quality oi crie NPDES
related inspection program. The Manual was deve L'ip-^;i in "'
/
//
W.
Washington, D.C. Stanley
Assistant Adminiscrator
SEPTEMBER 1976 for Enf orceit'.CAr.
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NPDES
COMPLIANCE EVALUATION INSPECTION MANUAL
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER ENFORCEMENT
COMPLIANCE BRANCH
JULY 1976
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Compliance Evaluation Inspection Manual
Table of contents
Section Page
Introduction i
I. Administration 1
IA Work Ethics 1
1. Professional Stature 1
2. Conflicts of Interest 1
3. Attire 2
4. Industry And Public Relations 2
5. Gifts, Gratuities, Favors, and Luncheons, Etc. 3
6. Attempted Bribery 3
IB Disclosure of Official Information 4
1. Request For Information 4
(a) General 4
(b) Media Contacts 5
2. Requests by State and Local Cooperating
Officials 5
3. Confidential Information 6
1C Diaries and Field Notes 7
1. Responsibility 7
2. Entries 7
3. Disposition of Diaries 8
II Preparation For Inspection 9
IIA General 9
IIB Objectives 9
IIC Inspector's Responsibility 10
IID Pre-Inspection Techniques 10
HE Procedures 11
1. Compliance Files: General 11
2. Compliance File: Industrial Wastes 13
3. Inspector's Obligation 14
4. Equipment Needed by the Inspector 15
5. Review of Inspection Check Lists 16
III Treatment Facility Inspection 17
IIIA Authority 17
IIIB General 18
1. Limitation of Inspection 18
2. Timing of Inspection 18
IIIC Objectives 19
HID Inspector's Obligations 19
HIE Inspection Procedures 21
1. Scope of Inspection 21
2. Pre-Inspection Discussion with
Management 21
3. Conducting the Inspection 22
(a) General 22
(b) Industrial 23
(c) Treatment Observations 24
TO?
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(d) Process Verification: Industrial 27
(e) Maintenance 27
IIIF Post Inspection Discussion with Management 28
IV Records And Reports Inspection 31
IVA Authority 31
IVB Objectives 31
IVC General 32
IVD Procedures 32
Conducting the Inspection 32
1. Cursory Inspections 32
2. In-Depth Inspections 35
3. Refusal to Allow Inspection 35
V Compliance Schedule Status Inspection 36
VA Authority 36
VB Objectives 36
VC General 37
VD Procedures 37
1. Inspector's Obligations 37
2. Conducting the Inspection 38
(a) Authorization and Financing 38
(b) Contract and Equipment Orders 38
(c) construction Progress 39
(d) Attainment of Operational Status 41
VI Self-Monitoring Program Inspection 43
VIA Authority 43
VIB Objectives 43
VIC Procedures 44
1. Inspector's Obligations 44
2. Conducting the Inspection 44
(a) Flow Measurement: Weirs 44
(b) Flow Measurement: Other Devices 45
(c) Flow Recording: Continuous 47
(d) Sampling 47
(e) Laboratory: On-Site 48
(f) Laboratory: Off-Site or Contract 50
VII Special Considerations And Techniques 52
VIIA Authority 52
1. Multi-Media Inspections 52
(a) Water 52
(b) Air 52
(c) Pesticides 53
VIIB Inspector's Responsibility 53
VIIC Procedures 54
1. Inspector's Obligations 54
2. Conducting the Inspection 55
(a) Multi-Media 55
(b) Air Pollution 56
(c) Land Pollution: Solid Waste 57
(d) Spill Prevention Control and
Countermeasure (SPCC) Plan 58
VIID Complaint Investigations 59
1. General 59
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2. Conducting Complaint Investigations 59
VIIE Photographs 61
1. General 61
2. Identification Requirements 62
VIII Federal And State cooperation 64
VIIIA Authority 64
VIIIB Objectives 64
VIIIC Policy 65
IX Safety 66
IXA General 66
IXB Safety Equipment 66
1. Personal Safety Gear 66
2. Safety Equipment 67
IXC Safety Precautions 67
Inspection and Operating Personnel 67
1. Authority 67
2. Inspector's Obligations 68
X Access And Warrants 69
XA General 69
XB Objectives 71
XC Unreasonable Search and Seizure 72
XD Denial of Entry For Review and/or Copy of Records 72
XE Privilege Against Self Incrimination 73
XI Compliance Evaluation Inspection Report 75
XIA Objective 75
XIB General 75
XIC Procedures 75
1. Inspector's Obligation 76
2. Compliance Evaluation Inspection
Report 78
XID Abbreviated Narrative Reports 78
Glossary 80
References 82
Section References 85
Appendix 86
IV
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COMPLIANCE EVALUATION INSPECTION MANUAL
INTRODUCTION
The objective of the Federal Watcr Pollution Control Act,
P.L. 92-500, as amended, is to restore and maintain the
cleanliness of the Nation's waters. The mission of the field
staff engaged in the enforcement of the Act is to implement the
plans that have been adopted to achieve the Act's objective,
thereby guarding the environment against the adverse effects of
water pollution.
A vigorous and thorough enforcement program, fairly but
firmly administered, is the best way to guarantee that the
mission will succeed. An effective enforcement program requires
highly-trained, well-qualified and dedicated personnel. These
qualities are essential in conducting inspections and
investigations to detect violations and to provide evidence to
support successful enforcement actions.
This manual is a guide for the professional field staff in
carrying out their responsibilities in field surveillance,
facility inspection and enforcement activities. It contains the
authorities, objectives, responsibilities, policies and
procedures required by the professional field staff to do their
job. It is not intended to cover every possible situation
confronting an active, dynamic inspection staff. It should
enable professional field personnel to perform in an effective,
efficient and knowledgeable manner.
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Although this manual is primarily designed for use by EPA
field staff, States having NPDES Enforcement authority may use
the manual in the orientation and training of State inspectors.
The manual was developed by a working group consisting of
Headquarters and Regional personnel ir luding:
1. Ira W. Thompson, Chairman, Washington, DC
2. James Patrick, Region IV
3. David Stoltenberg, Region V
4. Robert Reeves, Region VI
5. G.R. Stigall, Region VII
6. Gerald Klug, Region IX
7. David Shedroff, Washington, D.C.
8. Donald M. Olson, Washington, D.C.
Meetings were held in Washington, D.C., and the Regions to
obtain maximum regional input. Comments and suggestions were
requested from EPA Regional Offices, approved NPDES States,
selected Federal Agencies and Headquarters personnel. The
members of the Working Group wish to thank everyone for their
invaluable guidance and assistance in supplying the information
used in the preparation of this manual.
Based on their experiences with its use, holders of this
manual are encouraged to offer suggestions, revisions and
constructive criticism to the chairman of the Working Group.
This will aid the Working Group in making the necessary revisions
that keep the manual a useful working tool.
VI
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A permanent EPA Compliance Evaluation Inspection Manual
Committee will be formed consisting of two Headquarters and three
Regional representatives, one representative from the National
Field Investigations Center-Denver and one State representative.
The membership will be selected on an annual basis and the group
shall meet at least once annually to effect necessary changes and
additions to the manual.
As changes, revisions or deletions occur in the manual,
revised pages will be sent to you with a Compliance Evaluation
Inspection Manual transmittal notice. The notice will identify
and describe the new information being issued.
Each page of the manual is identified at the bottom with the
name of the manual and the date. At appropriate intervals, a
check list of current pages will be issued to show each page
number and its latest issuance date. When a new check list is
received, check the dates of the pages in your manual. Request
new pages from your supervisor as required.
VII
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SECTION I
ADMINISTRATION
1A WORK ETHICS
1. Professional Stature
Inspectors are expected to perform their duties in a
professional and responsible manner.
Inspectors shall:
(a) Develop and report the facts of an investigation
completely, accurately and objectively.
(b) Conduct themselves at all times in accordance
with the regulations in the EPA handbook
Responsibilities and Conduct For EPA Employees.
(c) Avoid, in the course of an investigation, any
act or failure to act which could be considered
to have been motivated by reason of personal or
private gain.
(d) Make a continuing effort to improve their
professional knowledge and technical skill in
the investigation field.
2. Conflicts of Interest
A conflict of interest may exist whenever an EPA
employee has a personal or private interest in a
matter which is related to his official duties and
responsibilities. It is important to avoid even the
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Section I; Administration
appearance of a conflict of interest because the
appearance of a conflict damages the integrity of the
agency and its employees in the eyes of the public.
All employees must, therefore, be constantly aware of
situations which are, or give the appearance of
conflicts of interest when dealing with others in or
outside of the government. For a detailed discussion
of the situations and/or activities which may result
in conflict of interest, the inspector is directed to
the publication Responsibilities and Conduct For EPA
Employees (FR.r Vol. 38, No. 73).
3. Attire
Good public relations and common sense require that
you dress appropriately for the activity in which you
are engaged. Consult your supervisor for regional
policy relative to proper attire and be guided
accordingly.
U. Industry and Public Relations
It is important that cooperation be obtained and good
working relations established when working with the
permittees and the public. This can best be
accomplished by using diplomacy, tact, and persuasion.
Even a hostile person should be treated with courtesy
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Section I: Administration
and respect. Inspectors should not speak of any
person, other regulatory agency, manufacturer or
industrial product in a derogatory manner. All
information acquired in the course of an inspector's
duties is for official use only.
5. Gifts, Gratuitiesr Favors, and Luncheons, Etc.
An EPA employee is forbidden to solicit or accept any
gift, gratuity, entertainment (including meals),
favors, loans, or any other thing of monetary value
from any person, corporation, or group which has a
contractual or financial relationship with EPA, which
has interests which may be substantially affected by
such employee's official actions, or conducts
operations which are regulated by EPA. Acceptance of
food and refreshments of nominal value, such as a
luncheon during a plant tour where the arrangements
are consistent with the transaction of official
business, is an exception to the above stated general
rule.
6. Attempted Bribery
You may be offered money in varying amounts by persons
whose activities you are investigating. Such
incidents usually arise from ignorance on the part of
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Section I; Administration
an individual who is unfamiliar with EPA Inspectors.
Other cases may be outright attempts to bribe you to
whitewash a serious violation or condition, or to
cause you to withhold dam?ging information or
observations. Inspectors shall:
(a) Ask "What is this for" if they are offered
something of value.
(b) Explain politely, if the offer is repeated, that
both parties to such transactions may be guilty
of violating the Federal Statutes.
(c) Not accept money or goods of any kind.
(d) Immediately report the incident in detail to
their supervisor.
IB DISCLOSURE OF OFFICIAL INFORMATION
1. Requests For Information
(a) General
EPA has an "open-door" policy on releasing
information to the public. It aims to make
information about EPA and its work available,
freely and equally, to all interested
individuals, groups and organizations. This
policy, however, does not extend to information
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Section I: Administration
relating to the suspicion of a violation or
evidence of possible misconduct.
(b) Media Contacts
Inspectors should cooperate with representatives
of the press, other communications media, and
interested groups. Information concerning the
Agencys responsibility for inspections and
monitoring activities can be given; but
questions concerning investigations of alleged
NPDES permit violations and water enforcement
policy should be referred to the Regional
Enforcement Director for response.
Requests by State and Local Cooperating Officials
State and local water enforcement officials,
cooperating with EPA in the enforcement and
implementation of the FWPCA, are permitted access to
official information subject to approval by the
appropriate regional official. Although inspectors
are not responsible for answering requests for the
release of confidential information, they should keep
informed as to who is permitted access to such
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Section I: Administration
information. Consult with your supervisor immediately
after receiving such a request.
3. Confidential Information
(a) Section 308 (b) of the FWPCA addresses the
protection of trade secrets and confidential
information.
(b) All confidential information received shall be
marked as such and placed in a locked filing
cabinet or a safe.
(i) Only personnel authorized by the Regional
Administrator, Division Director, or
Branch Chief shall be allowed access to
the file.
(ii) Copies of information marked "trade
secret" and/or "confidential" should not
be made unless authorized in writing by
the Regional Administrator, Division
Director, or Branch Chief.
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Section I: Administration
(c) Requests for access to confidential information
by any member of the public, or a state, local,
or Federal agency shaxj. be handled according to
the procedures contained in the Freedom of
Information Act JRegulations (UO CFR 2) . All
such requests shall be referred to the
responsible regional organizational unit.
1C DIARIES AND FIELD NOTES
1- Responsibility
Each inspector will maintain a legible daily diary
containing an accurate and inclusive documentation of
inspection activity. Since the diary will form the
basis for later written reports, it must contain only
facts and observations. Language will be objective,
factual and free of personal feelings or other
terminology which might prove inappropriate.
2. Entries
The government's case in a formal hearing or criminal
prosecution often hinges on the evidence gathered by
the inspector. Vigorous regional enforcement efforts
have increased the probability of inspectors being
called upon to testify. Therefore it is imperative
that each inspector keep detailed records of
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Section I: Administration
inspections, investigations, photographs taken, etc.
Field notes and observations should be maintained in a
bound, consecutively numbered notebook. This data
will serve as an aid in giving testimony.
3 Disposition of Diaries
The diary is a part of the EPA's regional files and
should not be considered the inspector's personal
record. Diaries shall be held in field offices
indefinitely, pending disposition instructions from
the Regional Enforcement Director.
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SECTION II
PREPARATION FOR INSPECTION
IIA GENERAL
Along with the review of self-monitoring reports, the
Compliance Evaluation Inspection and other investigation
efforts are compliance functions. Compliance Evaluation
Inspections must be designed to accomplish positive real-
world results not just the completion of a planned number of
inspections called for in a work schedule. These
inspections must be considered as an important mechanism in
the attainment of the Agency's goal of cleaning up the
nati on's waters.
IIB OBJECTIVES
The primary objectives of preparation for inspection are:
1. To obtain and review all Agency information essential
in conducting an effective inspection.
2. To permit completion of the scheduled number of
inspections in a timely manner.
3. To minimize inconvenience to permittees by not
requiring them either to explain or produce
information which is already in the hands of the
regulatory agency.
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Section II: Preparation for Inspection
IIC INSPECTOR'S RESPONSIBILITY
Inspectors are responsible for:
1. Knowledge of permit conditions, effluent limitations,
monitoring requirements, etc.
2. Knowledge of applicable EPA policies and procedures.
3. Short-range inspection scheduling.
U. Adequate pre-inspection planning.
5. The Compliance Evaluation Inspection itself.
6. Completion of follow-up procedures.
7. Adequate records maintenance.
IID PRE-INSPECTION TECHNIQUES
To achieve these objectives, several steps should be taken:
1. Review compliance files consisting of: pertinent
portions of permits and other related documents, prior
inspection reports, the permittees' self-monitoring
reports, and other reporting data for the
determination of compliance/non-compliance status.
2. Develop a "route system" for maximum utilization of
available inspection personnel.
3. Establish "phone-in" and "phone-out" procedures for
inspection and office personnel, respectively, to
insure that emergencies and urgent requests for
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Section II: Preparation for Inspection
immediate attention can be handled without unnecessary
travel or loss of time.
These steps will be outlined in more detail in the
succeeding sections of the Manual.
HE PROCEDURES
1. Compliance Files; General
Noted below are materials pertaining to the permittee
with which the inspector should be familiar prior to
making the inspection. Because a summary of the
information will be needed for future inspections, it
is recommended that a "compliance file" be prepared
for each NPDES permittee. When inspectors take such
files with them on inspections, it assures them that
needed information for timely completion of an
inspection is readily available. Afterwards, the file
can be updated for the next inspection.
Generally, the "compliance file" should include:
(a) A copy of the NPDES and applicable state
permits.
(b) A sketch or a copy of a U.S. Geological Survey
map showing the waste facility location and/or
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Section II; Preparation for Inspection
its effluent discharge point. Overflow and by-
pass discharge points should also be shown.
(c) A summary of names, titles, locations and phone
numbers of the responsible persons (operators,
municipal or industrial officials) involved with
the permittee's water pollution control
programs.
(d) A flow chart or summary of the present and
planned treatment and/or abatement facilities.
(If appropriate, include industrial production
processes.)
(e) Inspection reports from previous inspections.
(f) The permittee's most recent Compliance Schedule
and/or Discharge Monitoring Report.
(g) Letter of notification of inspection to the
discharger and the response (if applicable).
(h) Any other recent correspondence and/or
regulatory action, noting the status of
requested actions and/or compliance with
enforcement actions.
(i) Previous EPA studies, consultant's reports and
laboratory procedures describing non-routine
analyses.
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Section II; Preparation for Inspection
2. Compliance File: Industrial Wastes
Industrial waste discharge "compliance files" should
also include a plot plan of plant facilities showing:
(a) Sources of raw wat<^r supply (intakes, wells,
etc) .
(b) Water supply and waste treatment facilities.
(c) Drainage and wastewater collection systems,
including appurtenances such as catch basins.
(d) By-passes.
(e) Storage facilities, including solid waste
storage facilities.
(f) Monitoring stations.
(g) Effluent discharge points and receiving waters.
(h) Manufacturing operations on a process flow
sheet.
All inspectors should find the compliance file
inherently valuable. It will often assure an
efficient and complete inspection in a minimum amount
of time.
Special attention must be given to the pre-inspection
review of names, titles and hierarchical relationships
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Section II: Preparation for Inspection
of the operating and/or administrative personnel for
each permit. As a fundamental component of field
inspection effectiveness, trie cooperation of municipal
and industrial officials involved in pollution control
is essential. This cooperation is dependent upon a
satisfactory professional relationship between the
Agency, industry, municipal and state personnel as
well as upon a deserved respect for the technical
proficiency of the Agency's inspectors.
3, Inspector's Obligation
The inspectors should:
(a) Review and become familiar with the essential
information in each "compliance file" before the
on-site visit.
(b) Review the "routing system " for scheduled
inspections to insure that all inspections are
conducted to optimize time and minimize
expenses.
(c) File projected route and stops with supervisor
before leaving on the inspection trips.
(d) Check to see that a "Letter of Notification" of
inspection has been sent to permittees whose
facilities are scheduled for inspection. It
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Section II: Preparation for Inspection
should be noted, however, that in certain cases
where illegal discharges or dumping are
suspected, prior notification may not be
practical or appropriate. The recommended
"Letter of Notification" is shown in Exhibit "A"
in the Appendix of this Manual.
4. Equipment Needed by the Inspector
Depending on the facilities to be inspected equipment
should consist of some or all the following items.
(a) Personal Protection
See Section IX of this Manual, Safety.
(b) Miscellaneous
(i) Camera
(ii) Pocket
calculator
(iii) Thermometer
(iv) Sample bottles
(vii) Psychrometer
(viii)Range finder
(ix) Tape measure
(x) Compass
(xi) Stopwatch
(v) Clip board (with (xii) Wind meter or
appropriate Admiral Beauford
check-list) Wind Scale
(vii) Level (xii) Square
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Compliance Evaluation Inspection Manual
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Section II; Preparation for Inspection
It should be noted that this is a minimum list of
equipment which may be required by the inspector.
However, it is recognized t^at all the equipment may
not be needed on any given inspection. Many of the
items are primarily for air compliance monitoring
inspections and should also be routinely carried on
Compliance Evaluation Inspections since Compliance
Evaluation Inspections may serve as multi-media (air
and water) inspections.
5. Review of Inspection Check Lists
To insure that all necessary areas of concern are
reviewed during the inspection, a series of checklists
have been developed for use by the inspector. These
recommended check lists are contained in Exhibit "B"
of this Manual. If the inspector's organization has
already developed check lists that include these
points (as a minimum), such check lists may be
substituted. The check lists should be used as a tool
for insuring a comprehensive review but should not be
used as a substitute for judgement.
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SECTION III
TREATMENT FACILITY INSPECTION
IIIA AUTHORITY
Section 308 of the Act authorizes the Administrator to
require the owner or operator of any point source to:
1. Establish and maintain certain records,
2. Prepare certain reports,
3. Install, use, and maintain certain monitoring
equipment or methods (including biological monitoring
methods where appropriate),
4. Sample effluent as prescribed, and
5. Provide certain other information that may be
reasonably required.
Also, the Administrator, or his authorized representatives
(which include EPA inspectors) are authorized to:
(a) Enter into, upon or through premises in which an
effluent source is located or in which any
records required to be maintained are located,
and,
(b) At reasonable times, have access to and copy any
records, inspect any required monitoring
equipment or method and sample any effluents
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Section III: Treatment Facility Inspection
which the owner or operator is required to
sample.
Under section 309 of the Act, L. A can issue a compliance
order or bring a civil action for a wide range of violations
of any Section 308 related NPDES permit condition.
IIIB GENERAL
1. Limitation of Inspection
The Compliance Evaluation Inspection program will
normally be restricted to inspections of effluent
discharge sources in support of the NPDES permit
program. However, other sources of water pollution or
potential pollution, including non-point sources,
observed by Compliance Evaluation Inspectors should
not be ignored. They should be reported to the
appropriate EPA organizational unit or State Water
Pollution Control Agency for proper action.
2. Timing of Inspection
All inspections should be conducted at "reasonable
times" as defined in Section X of this Manual, Access
and Warrants. Occasionally, it will be necessary to
conduct inspections of industrial facilities and
municipal wastewater facilities which treat major
industrial wastes during times other than week day
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Section III: Treatment Facility Inspection
shifts. Standard, day-shift flows may not always be
truly representative when industries or contributing
industries operate on a scv^n-day or multi-shift basis
because of process flow variations and process
discharge procedures.
II1C OBJECTIVES
The objectives of a Compliance Evaluation inspection are:
1. Observe the status of construction required by the
permit.
2. Assess the adequacy of the permittee's self monitoring
program.
3. Check records which are required to be maintained by
the permittee.
4. Assure that permit requirements are being met.
5. Make recommendations as to need for follow-up
activities.
HID INSPECTORS OBLIGATIONS
In making field contacts, the principles or rules an
inspector should follow are:
1. Enter the permittee's premises through the main gate
or through the entrance designated by the permittee in
response to the inspection notification letter.
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Section III: Treatment Facility Inspection
2. In a dignified, courteous manner, introduce yourself
as an EPA inspector to the cwner, operator or agent in
charge.
3. Present your official EPA credentials whether or not
identification is requested.
U. Do not sign "waiver11 or "visitors releases" (U.S.EPA
inspectors only) that absolve the permittee of
responsibility for injury due to the permittee's
negligence.*
6. If possible, make prior arrangements for a joint
inspection with the operator in those cases where
full-time attendance is not provided.
7. Complete the inspection in a timely manner. Any
problems experienced that greatly forestall or prevent
the completion of the inspection should be reported
promptly to your supervisor.
*NOTE (See Memorandum of the Assistant Administrator
for Enforcement and General Counsel, November 8,
1972) . If the owner refuses entry without a signed
waiver, the inspector should refuse to sign it, leave
and immediately report the matter to the Regional
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Section III; Treatment Facility Inspection
Enforcement Director in the same manner as other
refusals of entry (See Section X of this Manual).
HIE INSPECTION PROCEDURES
1. scope of Inspection
(a) The inspection of any permittee's premises
includes: Any building, structure, facility or
installation from which there is or may be the
discharge of pollutants.
(b) The areas of the permittee's premises to which
the inspector has access are all areas where:
(i) Pollutants are generated, pumped,
conveyed, treated or stored or may be
discharged.
(ii) Records referred to in Section 308 of the
Act or in the discharger's NPDES permit
are located.
(iii) Any monitoring equipment or monitoring
methods referred to in the NPDES permit
are located or conducted.
2. Pre-lnspection Discussion with Management
(a) If necessary, the inspector should explain that
Section 308 of the Act authorizes entry into any
premises from which there are or may be the
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Section III; Treatment Facility Inspection
y
discharge of pollutants or in which any records
required to be maintained are located.
(b) Discuss other applicable provisions of the Act
and, if requested, furnish a copy of the Act and
appropriate regulations. If such information is
not readily available, the inspector should
inform the permittee where it may be obtained.
A joint review of most recent self-monitoring reports and field
reports is usually mutually beneficial, especially if violations
or apparent violations of discharge requirements are involved.
The inspector's assistance may be requested by some operators in
the prevention of problems that result in discharge violations.
However, the inspector should be careful not to offer direct
plant operating advice or issue instructions.
3. Conducting the Inspection
(a) General
To fully evaluate the overall plant operation an
inspector should have a full understanding of
each treatment process, how each process fits
into the overall treatment process and the "up-
stream" conditions that affect treatment
operations. A good understanding of operating
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details is invaluable to the inspector in
evaluating the operating results and the extent
to which the operatJn^ personnel understand how
the unit operations and processes, individually
and collectively, perform their functions.
(b) Industrial
Because of the wide variety and the complex
nature of industrial wastes, special knowledge
and techniques are essential for adequate
compliance inspection of industrial facilities.
The inspector must have knowledge of:
(i) Industrial flow diagrams of raw water,
production use, raw materials, additives,
end products, by-products,- and liquid,
gaseous and solid wastes.
(ii) Water consumption, distribution, usage and
the hydraulics of drainage and collection
systems for process waters and industrial
wastewaters.
(iii) Production processes, materials used,
"dump" schedules, treatment required,
treatment equipment, wastewater
characteristics and methods of treatment
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and disposal of sludge and other treatment
residuals.
On an initial facility visit, it may be
advantageous to have the plant engineer or chief
operator describe the plant and its principal
operating characteristics as a supplement to the
inspector1s review of plans from the compliance
file. This step will help to orient you and
give you an indication of how well the operating
personnel understand the system.
(c) Treatment Observations
During the plant tour the inspector should be
alert and inquire about:
(i) Accumulations of solids and scum in wet
wells, excessive scum buildup, grease,
foam or floating materials in tanks.
(ii) Surcharging of influent lines, over-flow
weirs and other structures.
(iii) Obnoxious odors in wet wells, grit
chambers, around aerobic and anaerobic
biological units, scum removal devices and
sludge handling facilities.
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Section III; Treatment Facility Inspection
(iv) Vital treatment units out of service for
repairs. Determine when they were taken
out of service, the type of failure and
when the units will be put back in
service.
(v) Excessive weed and tule growths in
stabilization ponds, etc. Check earthen
retention walls (dikes) for breaches,
leaks and maintenance.
(vi) Freezing wastewater in ammonia stripping
towers and formation of excessive calcium
carbonate deposits on tower structures,
fouling of fabric in microscreens with
grease and solids and mechanical fouling
of activated carbon columns.
(vii) Alternate discharge points, channels or
other areas likely to have overflows.
(Inspect to see if spills or unauthorized
usage has recently occurred as a result of
the operating personnel attempting to
correct operational problems.)
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Section III: Treatment Facility Inspection
(viii)Sludge decomposing in clarifiers as
indicated by gas bubbles rising to the
surface or by floating sludge pads.
(ix) Any unusal equipment such as special
pumps, floating aerators in diffused air
systems, chemical feeders, temporary
construction or structures, or any jerry-
rigged systems intended to correct
operational problems.
(x) Excessive suspended solids, turbidity,
foam, grease, scum, color, and other
macroscopic particulate matter in the
plant effluent and the receiving waters.
(xi) Collected screenings, slurries, sludges or
other by-products of treatment. Their
disposal, including the runoff of
wastewaters, must be in such a manner as
to prevent entry into navigable waters or
their tributaries.
(xii) Adequate safeguards to prevent the
discharge of untreated or inadequately
treated wastes during electrical failures.
(xiii)Infiltration and inflow problems.
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(d) Process Verification: Industrial
Industries frequently make production changes because
of the introduction of new technology, new products,
new processes, etc. Therefore, the industrial waste
inspector should inquire:
(i) If a permittee has made any changes in
production processes, raw materials, amount of
finished product, water usage, waste treatment
processes and other such changes. Specifically,
the inspector should determine if the permittee
has made changes that would increase the
discharge of pollutants above the effluent
limitations specified in the issued NPDES
permit.
(ii) If the EPA (or the state) was notified of such
changes. The inspector should verify any
changes and include the results of the findings
and other pertinent information in the
Compliance Evaluation Inspection report.
(e) Maintenance
Good operation and good maintenance go together. Good
maintenance indicates that plant operating personnel
are giving adequate emphasis to the plant's facilities
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and performance. Sloppy maintenance may indicate the
operator's lack of concern or ability. The usual
result is a number of problems, including poor
operation and the discharge of excessive pollutants
into the receiving water and/or atmosphere.
The inspector should inquire about the maintenance
programs for:
(i) All mechanical equipment (i.e., pumps, clarifier
scraper mechanism etc.)
(ii) Guardrails and safe walkways around and between
tanks, pits, and major units.
(iii) Condition of safety/reinforcing mechanisms or
devices.
(iv) Proper lighting.
(v) Cleaning of areas where waste allowed to
accumulate.
(vi) Protective paint on units and color coded piping
systems.
IIIF POST INSPECTION DISCUSSION WITH MANAGEMENT
To achieve the most effective results from Compliance
Evaluation Inspections, it is essential to have timely
communication of the results to management and/or operating
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personnel. Failure to discuss the results can cause a loss
of mutual respect. When this occurs, it is a deterrent to
good inspector-operator relations and understanding.
However, the inspector* s discussion should be limited to
specific findings of the visit. If appropriate, a comparison
of these facts with the permittee's NPDES permit
requirements should be made.
Precautions and Guidelines
Although a discussion of the inspection results is
important, certain precautions are essential.
The inspector must:
(a) Realize that it is an unacceptable practice to
recommend a particular consultant or consulting firm
even if asked to do so. However, it is not unethical
to inform the permittee, operator or agent, to contact
a professional society for advice concerning this
matter.
(b) Make no attempt to substitute your own judgement for
that of plant operating personnel regarding details of
operation.
(c) Remember that your function is to observe and evaluate
compliance while on Compliance Evaluation Inspections.
The overall compliance or noncompliance status of the
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facility is determined by the Enforcement Division
upon review of the Compliance Evaluation Inspection
Report. Statements regarding compliance status and
any legal effects or enforcement consequences should
not be discussed with the permittee or facility
operating personnel.
These guidelines are subject to applicable rules
promulgated by the Regional Administrator or State
Director regarding permittee contacts in the
region/state.
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SECTION IV
RECORDS AND REPORTS INSPECTION
IVA AUTHORITY
Section 402 of the Act authorizes the National Pollutant
Discharge Elimination System. The NPDES permit system
requires permittees to maintain records and to report
periodically on the amount and nature of the waste
components in their effluents. Section 308 of the Act
authorizes inspections of such required records and reports.
IVB OBJECTIVES
The main objectives of a records and reports inspection are
to:
1. Assess compliance with the discharger's NPDES permit
limitations and requirements.
2. Allow Federal and State regulatory agencies to follow,
on a continuing basis, the discharger's effluent
quality trends as well as specific variations from
established limitations.
3. Help define the scope of a suspected violation and
thereby enable the regulatory agency to focus the
direction of its follow-up action.
u. Determine if the records and reports required by the
discharger's NPDES permit are being maintained.
5. Check on the adequacy of the permittee's reports.
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IVC GENERAL
Inspection for the purpose of determining compliance with
the Agency's record keeping and report filing requirements
generally will be limited to an inspection sufficient to
determine if the permittee (1) keeps and files the required
records, (2) maintains records in an up-to-date manner, (3)
retains them for the time period required by the NPDES
permit and (4) needs assistance on how to comply with the
regulatory agency's requirements on records and reports.
In-depth inspection of permittee's records and reports will
be conducted only when necessary to substantiate a suspected
violation, verify self-monitoring data which may be used as
corroborative evidence in an enforcement action, to confirm
apparent sampling, analysis or reporting discrepancies
discovered during the limited inspection.
IVD PROCEDURES
Conducting the Inspection
1. Cursory Inspections
On an initial visit to a permittee's premises, the
inspector should discuss the recordkeeping and
reporting requirements with management. This type of
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inspection should use the check list provided in
Appendix "B" and be limited to the verification of:
(a) The maintenance of sampling and analysis data.
(b) The maintenance of daily operating logs. These
are important and they should be bound in
notebooks to prevent their alteration or
destruction. Information on the daily log sheet
for a municipal plant should include:
(i) A summary of all lab tests run.
(ii) A format for calculating BOD and
equivalent tests.
(iii) Weather conditions (temperature,
precipitation, etc.)
(iv) Chemicals used such as pounds of chlorine
used per day.
(c) The maintenance of management generated records,
such as average monthly operating records and
annual reports, emergency conditions, such as
power failures, by-pass and chlorine failure
reports. These records should be requested to
facilitate the inspector's review but the
permittee is only required to prepare and
maintain those as specified by the NPDES permit.
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(d) The maintenance of pretreatment records,
including industrial waste ordinance (or
equivalent documents), inventory of industrial
waste contributors including
compliance/noncompliance records and user charge
information.
(e) The maintenance of laboratory records including
all original strip charts from continuous
monitoring instrumentation and calibration and
maintenance records.
(f) The maintenance of physical plant records* at
the plant for reference. These include:
(i) O6M Plant Manual. (Municipal only)
(ii) "As built" engineering drawings.
(iii) Copy of construction specifications.
(iv) Equipment supplier manual.
(v) Data cards on all equipment
(g) A properly completed Spill Prevention Control
and Countermeasure rlan, if required.
(h) The retention of records for a minimum period
of three years beginning with the issuance date
of the permittee's first NPDES permit.
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(i) The conformity of required self-monitoring
results with permit requirements and consistency
with other operating data.
*NOTE: Preferably, these items should be available
but they are only required for those facilities built
with Federal construction grant funds.
2. In-depth Inspections
This inspection may be conducted primarily to check
records and reports. For example, such an inspection
may be warranted:
(a) If the self-reported data are suspected to be
grossly inaccurate and the problem is believed
to be with the recordkeeping and/or the filing
of reports,
(b) If the discharge does not meet required
standards and no definite operational problem
areas have been established.
(c) If the cursory inspection indicates omissions or
laxity in the preparation of records.
3. Refusal to allow inspection
Consult Section X of this manual and advise your
supervisor of the refusal to allow inspection and/or
copy of records.
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SECTION V
COMPLIANCE SCHEDULE STATUS INSPECTION
VA AUTHORITY
Pursuant to the general authority to issue permits in
Section 402 of the Act, regulations have been issued
outlining procedures to be followed in setting compliance
schedules for permittees whose abatement facilities require
modification in order to meet the effluent limitations set
forth in section 301 of the Act - e.g., BPCTCA for
industrial dischargers prior to July 1, 1977. These
regulations, (40 CFR 125.23) relating to Federally issued
permits require the permittee to furnish periodic reports of
progress and current status.
This section has no application if the permit does not
contain a compliance schedule ( see section VC).
VB OBJECTIVES
The objectives of this phase of the Compliance Evaluation
Inspection are to determine:
1. The accuracy of reports relating to compliance
schedules.
2. Whether the permittee is currently conforming to the
compliance schedule, and if not, whether final
requirements will be achieved on time.
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Section V; Compliance Schedule Status Inspection
3. Whether schedule violations, if any, are the result of
matters beyond the control of the discharger.
4. The delay associated with a particular construction
violation.
5. Whether requests for permit modifications have a valid
basis.
VC GENERAL
All point source dischargers shall conform to treatment
requirements set forth in section 301 of the Act. The
Agency is concerned that compliance schedule status be
determined at critical intervals to assure that abatement is
attained on schedule. On all inspections conducted after
final effluent limitations have been achieved, this phase of
the inspection is not appropriate.
VD PROCEDURES
1. Inspector's Obligations
The inspector should determine whether these
objectives are being achieved. To do this properly,
the inspector must become thoroughly familiar with the
compliance schedule requirements of the permit and
with the permittee's progress reports. The inspector
must be able to review plans, specifications,
construction and equipment contracts, change orders.
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Section V: Compliance Schedule Status Inspection
and visually estimate installation progress using the
check list provided in Appendix "B". A review should
be made of appropriate documents and a visual
inspection made of construction and equipment
installation.
2. Conducting the Inspection
(a) Author ization and Financing
If the necessary treatment works are not in
place, the inspector should ascertain whether
the permittee has authority to construct the
necessary installation (corporate resolutions,
etc.) and has made arrangements for proper
financing (mortgage commitments, etc.) .
(b) Contract and Equipment Orders
The inspector should review the appropriate
documents to determine:
(i) If contracts for engineering services have
been executed. Review to determine the
specific date of execution and dates for
completion of design plans and
specif ications.
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(ii) That the permittee has obtained the
necessary approvals from the appropriate
agencies in order to begin construction.
(iii) If bids have been advertised. Review a
copy of the advertised "sealed proposal".
(iv) If construction contracts have been
executed. Review to determine the dates
of execution, the start, completion and
scope of construction.
(v) If equipment contracts have been executed.
Review to determine their validity, the
name and address of the supplier, the
dates of execution, schedule delivery
dates, and the identification of
equipment.
(c) Construction Progress
In this area it is important to know if
contracts for labor and material are timely and
that the permittee or his engineering consultant
are monitoring progress. These aspects are
extremely important particularly for plants
where there is likely to be a multiplicity of
contracts for labor and equipment. The
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Section V: Compliance Schedule Status Inspection
inspector will learn to "eye ball" construction
progress and be able to estimate the percentage
of completion. If the construction or equipment
acquisition is behind schedule, it is
appropriate for the inspector to:
(i) Ask to see the permittee's or the resident
engineer's progress report and determine
whether the final compliance schedule date
can be met as required by the permit.
(ii) Advise the permittee, if the response is
negative, that the compliance schedule
requirements of his NPDES permit requires
him to notify the permit issuing authority
promptly of any possible delays in
achieving compliance and measures he has
taken to minimize the delay.
(iii) Inquire whether the facility
superintendent or chief operator and
operating personnel are receiving adequate
training while construction work is in
full progress. They must be ready and
have the capability to perform the minimum
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essential functions when the facility is
placed in service.
(d) Attainment Of Operational Status
If construction has been completed but
operational status not yet attained, the
inspector should determine whether appropriate
procedures are being used to assure attainment
of working levels at the earliest possible time.
The inspector should verify whether:
(i) Adequate self-monitoring program
procedures have been initiated. It is
especially appropriate that the
operational and effluent quality results
be reviewed to determine whether progress
is being made toward optimum efficiency in
each treatment unit and in the entire
plant.
(ii) Adequate work schedules and assignments
have been established. For municipal
facilities, the OSM manual should provide
the essential guidance in this regard.
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(iii) Adequate record keeping procedures have
been established and initiated.
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SECTION VI
SELF MONITORING PROGRAM INSPECTION
VIA AUTHORITY
Section 308 (a) (B) (ii) of the Act authorizes the
Administrator or his authorized representative, upon
presentation of credentials, to inspect monitoring equipment
or methods required by permits issued under the NPDES
program. section 308 (c) authorizes States to develop
equivalent programs under State law for inspection,
monitoring and entry with respect to point sources (other
than federal installations) located within such States.
VIE OBJECTIVES
The objective of this phase of the Compliance Evaluation
Inspection is to:
1. Confirm that the sampling and flow measurement
equipment are provided as required in the permit and
that they are being operated and maintained properly.
2. Verify that the analyses are being performed with the
proper equipment and by persons who have the requisite
skills.
3. Confirm that the analytical test methods used for
pollutants or parameters specified in NPDES permits
conform with the Agency's regulations as specified in
the Federal Register (40CFR 136).
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Section VI; Self Monitoring Program Inspection
VIC PROCEDURES
1- Inspector's Obligations
The inspector should determine the conformance of the
permittee's self-mcnitoring program with the permit
and appropriate regulations. To do this properly the
inspector must become thoroughly familiar with the
monitoring requirements as contained in the permit and
any pertinent correspondence which may have modified
or reestablished sampling points or analytical
procedures. Using the check lists provided in Exhibit
"B" entitled Self-Monitoring Program Check List, a
review should be made of appropriate documents and a
visual inspection made of flow measurement, sampling
and analytical equipment and facilities.
2. Conducting the Investigation
(a) Flow Measurement: Weirs
The inspector should confirm that flow
measurement devices utilized are appropriate for
the waste stream being measured. In addition,
the inspector should verify that each device is
free of sticks, rags and other debris and that
it is properly installed. Proper installation
of a weir means that:*
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(i) The device is installed exactly level
(ii) The weir platu is plumb and the top edge
is sharp and clean
(iii) There is free access for air to the
underside of the nappe of the overflowing
M
stream
(iv) The channel upstream from the weir is
reasonably straight, level and free from
disturbing influences so that the stream
assumes a quiet flow
(v) The stilling basin is of sufficient size
*NOTE: These criteria apply to a sharp-crested
weir. However, a permittee could have a broad-
crested weir with a developed rating curve. The
inspector should verify that the proper curve is
being used.
Flow Measurement: Other Devices
Other types of flow measuring devices used in
municipal and industrial applications include:
(i) Parshall flume
(ii) Venturi meter
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Section VI; Self Monitoring Program Inspection
(iii) Magmeter
(iv) Palmer-Bowlus flume
(iv) Orifice Meter
It is not within the province of this Manual to
discuss and describe the various flow
measurement devices since those details are
readily available in other publications. For
such detailed information the inspector should
consult the EPA Handbook For Monitoring
Industrial Wastewater ,the Department of
Commerce/National Bureau of Standards
Publication 421, A Guide To Methods And
Standards For The Measurement of Water Flow or
the Department of interior Bureau of
Reclamation's Water Measurement Manual.
All flow measuring devices are subject to calibration.
Therefore, the inspector should check to determine if
calibration records are available, the most recent
date of calibration and the flow measurement accuracy
obtained. Then comparison should be made with the
manufacturer's accuracy for the device. The inspector
should check to see if proper and accurate rating
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Section VI; Self Monitoring Program Inspection
curves or tables are beinq used for accurate
measurement of flows.
(c) Flow Recording; Continuous
Some NPDES permits specify "continuous" flow
measurement. This requires permanent recording
devices with a strip chart or circular chart. The
inspector should verify that a continuious recorder
exists, that it is being operated properly, and that
flow records are being kept on file.
(d) Sampling
The inspector should verify:
(i) That samples are taken at the locations
prescribed in the NPDES permit.
(ii) That the sampling location specified in the
permit is adequate to provide a well mixed and
representative sample.
(iii) That the frequency of sampling (grab samples
and sampling interval for composites) is done in
accordance with the NPDES permit.
(iv) That grab sample devices, if used, are clean
and are properly operated.
(v) That sample containers are clean and appropriate
for the parameter or parameters to be analyzed.
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(vi) That automatic sample collectors, if used,
operate properly. In hot weather, refrigeration
should be provided for certain parameters such
as BOD. In winter, protection from freezing may
also be necessary.
(vii) That proper chemical preservatives are used for
(time) composite samples and for grab samples
which are not analyzed immediately following
sample collection.
(viii)That samples are received and analyzed within
holding times specified in the appropriate
method of analysis.
(ix) If there is more than one sampling point,
determine that appropriate measures are used to
prevent cross contamination between samples and
that sample containers are properly identified.
(x) That all field testing equipment is routinely
calibrated.
(e) Laboratory; On-Site
The inspection of on-site analysis should verify:
(i) That the specific methods of analysis used are
approved for the particular parameter, or an
approved alternate method.
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Section VI; Self Monitoring ProgramI.n3£ec_iju»n
(ii) That the Idboiatoiy has written instructions on
the methodology er>.nloyed.
(iii) That quality Control methods such as the
analysis of blank, si)iir«;d, and split samples are
employed.
(iv) That the presence o± Known interferences in the
analyzed samples is established and steps taken
to remove the interferences.
(v) That laboratory personnel are familiar with the
analysis being peifoimeci including:
Procedure's for cleaning equipment,
Rr-aqen1 qc^iitv control, including source
of distilled water, trequericy ot reagent
standardization,, and reagent shelf life.
Media preservation and sterilization
techniques.
Use of bench cards and/or notebooks.
Use of uX'ailai'le analytical
inst r umtnt ct t i or;.
Calculation of results.
(vi) That where more than one person routinely
performs portions of particular analysis, the
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Section VI: Self Monitoring Program Inspection
person performing a specific portion should be
identified by a "sign-off" procedure.
(vii) That for analyses performed using automatic
sampling and analytical instrumentation, the
device (s) should be identified by manufacturer,
model etc., and the operation, calibration and
procedures followed should be noted.
(viii)That the location of the laboratory equipment
and/or instrumentation should be noted.
(f) Laboratory: Off-Site or Contract
For "off-site" analyses performed by a contract
laboratory, the inspector should verify:
(i) The name and address of the contract laboratory.
(ii) The permittee's procedures for the labeling and
shipping samples to the contract laboratory.
(iii) That the results reported by the laboratory use
the discharger's identification code number.
If any deficiencies* are uncovered as a result of the
inspection of the permittee's laboratory facility
and/or procedures, a specialist should be contacted
to determine whether an in-depth evaluation of the
subject laboratory is warranted.
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*NOTE: Inspectors should be careful not to draw the
hasty conclusion that a permit violation exists every
time deficiencies are uncovered. Nevertheless, they
should always be called to the Enforcement Division
Director's attention for appropriate corrective
action.
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SECTION VII
SPECIAL CONSIDERATIONS AND TECHNIQUES
VIIA AUTHORITY
1- Multi-Media Inspections
(a) Water
The Agency's authority under Section 308 of the
FWPCA is discussed in Section III of this
Manual.
(b) Air
Section 11U of the Clean Air Act (P.L. 93-319)
authorizes qualified inspectors upon
presentation of credentials:
(i) To enter any premises in which an emission
source is located or in which any records
required to be maintained under the Act
are located;
(ii) To, at reasonable times, have access to
and copy any records and inspect any
required monitoring equipment;
(iii) To sample any emissions which the owner or
operator is required to sample.
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Section VII: Special Considerations and Techniques
(c) Pesticides
Section IX of the Federal Insecticide, Fungicide
and Rodenticide Act, as ammended, allows a duly
authorized inspector to inspect and obtain
samples of pesticides or devices (after release
for shipment) and samples of containers and
labeling.
VIIB INSPECTOR'S RESPONSIBILITY
It is the inspector's responsibility to assure that:
1. Special consideration and techniques are used in
Compliance Evaluation Inspections wherever possible.
2. The Agency's goals in abating and controlling
environmental pollution are carried out without undue
delay.
3. The Agency's credibility is maintained by reporting
all known sources of environmental pollution to the
appropriate federal and/or state personnel for
appropriate action.
4. All media inspections be totally coordinated to ensure
full compliance with all environmental requirements.
5. All photographs used for documentation are properly
labeled and referenced to ensure admissibility as
evidence.
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VI1C PROCEDURES
1. Inspector's Obligations
Inspectors shall:
(a) Report all readily observable sources of
environmental pollution and occupational health
and safety hazards to their immediate
supervisors.*
(b) Become familiar with readily observable
indicators of environmental pollution and any
health or safety hazards encountered when making
inspections.
(c) Be aware of the basic environmental requirements
in other media programs to which a specific
source is subject.
(d) Be adequately trained in the use of special
techniques generally employed for a particular
medium program before conducting in-depth
inspections. However, for cursory inspections,
inspectors need not be well versed on all
environmental programs but only capable of
identifying potential problems.
*NOTE: Compliance Evaluation Inspectors should not
attempt any type of environmental inspection unless
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their credentials authorize such activity, and then
only in compliance with all statutory requirements.
2. Conducting Inspections
(a) Multi-Media
In addition to water, inspectors should be
capable of investigating a facility's compliance
status with respect to air and land (solid
wastes) environmental requirements.
One area where multi-media inspections should be
made is at a wastewater treatment facility where
two or more types of environmental pollution
(common source pollution) are evident. For
example, excessive odor problems at aerobic
biological treatment facilities may be
accompanied by the discharge of an inadequately
treated effluent.
Multi-media inspections must be properly
coordinated with appropriate inspection
personnel of other environmental programs. This
procedure is essential to avoid a duplication of
effort and/or multiple coverage of an
establishment by more than one inspector. In
any case, inspectors should:
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Section VII; Special Considerations and Techniques
(i) Inquire about the apparent cause and
sources of common source pollution.
(ii) Determine the steps being taken to abate
it.
(iii) Include the above information in the
inspection report.
(b) Air Pollution
Some of the readily observable indicators of air
pollution sources include:
(i) Heavy plumes of black smoke.
(ii) Excessive and unusual odors.
(iii) Excessive dust and fugitive emissions.
(iv) Severely damaged vegetation.
(v) Excessive corrosion.
(vi) Dust build-up on nearby homes, cars and
roads that could result from emissions by
a source.
For additional information on air pollution
inspection techniques, inspectors should refer
to the reference on this subject listed in the
appendix of this manual especially EPA Visible
Emission Inspection Procedures, and Guidelines
for Evaluation of Visible Emissions.
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Section VII: Special Considerations and Techniques
(c) Land Pollution; Solid Wastes
Sanitary landfills and incinerators are also
types of waste disposal facilities amenable to
multi-media inspections as these sites are
often:
(i) Used for the ultimate disposal of solid
residues resulting from the treatment of
wastewaters.
(ii) Located near treatment facilities and
frequently owned and operated by the same
NPDES permittees.
(iii) Sources of gross surface and/or ground
water pollution.
Inspection of these facilities is often
essential to determine compliance with FWPCA or
NPDES permit requirements. Multi-media
inspections at such facilities can be readily
conducted in minimum time with minimal expense.
Readily observable indicators of pollution
and/or improper operations at solid waste
disposal sites include:
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Section VII; Special Considerations and Techniques
(i) Refuse in direct con-tact with surface or
ground waters including water ponding on
site.
(ii) Leachate from the site entering surface
and/or ground waters.
(iii) Excessive odors and/or smoke.
(iv) Lack of maintenance of surface water
diversion barriers or dikes.
(v) Inadequately incinerated solid wastes.
(vi) The acceptance of toxic or hazardous
wastes for disposal at a site where such
wastes are not permitted.
(d) Spill Prevention Control and Countermeasure
(SPCC) Plan
It is important that inspectors determine if
permittees have prepared a SPCC plan of oil
storage facilities having sufficient capability
to subject them to the requirements of the Oil
Pollution Prevention Regulations (10CFR part
112^. However, this determination is not
applicable to facilities which have been
previously inspected for SPCC compliance.
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Section VII: Special Considerations and Techniques
VIID COMPLAINT INVESTIGATIONS
1. General
Every public agency, includinq EPA, is the recipient
of many citizen's complaints. From a public relations
standpoint, complaints should be welcomed from those
the Agency is supposed to serve since this is one of
several ways in which its overall surveillance
activities may be improved. In any case, field
surveillance personnel may be called upon to
investigate complaints that concern reports of alleged
pollution, inquiries regarding discharges and requests
to abate specific problems.
2. Conducting Complaint Investigations
Certain steps should be followed in handling them.
The first is determine if sufficient information is
available to conduct an investigation. This should
include:
(a) The complainant's name, address and telephone
number.
(b) Exact location of the alleged discharge or
conditions the complainant made reference to.
(c) Details of the complaint.
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Section VII; Special Considerations and Techniques
The next step is to check at once, if possible,
whatever records exist that might substantiate or
disprove the complaint. Following this, the
appropriate State agency should be contacted to
determine whether it has any information regarding the
complaint and whether it wishes to make a joint
investigation. If possible, the operator or agent in
charge of an alleged discharge should also be present
during the investigation. In some instances, it is
desirable to have the complainant present during the
investigation. However, circumstances will dictate
whether or not this is wise.
If the complaint concerns a wastewater discharge, the
same information should be reported as for a
Compliance Evaluation Inspection, including the
circumstances of any property damage, fish, bird or
wildlife kills or injuries.
When the investigation has been completed, the
discharger and complainant should be informed of the
results and that each can expect a timely written
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Section VII; Special consideration! and Techniques
response regarding the appropriate action that will be
taken to correct the problem.
VI IE PHOTOGRAPHS
1. General
The Agency has the right to take photographs of:
(a) Overall view, where possible, showing
arrangement, relative size and general condition
of the facility.
(b) All sampling points.
(c) Major process units within the waste treatment
facility.
(d) Operation and maintenance conditions.
(e) Effluent discharge points.
(f) Receiving water areas.
Photos should be keyed to the plot plan, flow diagram
or location on the map. It is always desirable to
obtain management's approval before taking
photographs. If there are objections to the use of
camera, explain in a tactful manner that the
photographs will enable you to prepare a more thorough
and accurate inspection report. Facility modification
and/or additions and changes in effluent or receiving
water conditions should be recorded as they occur with
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Section VII: Special Cons ijler at ions _ -hai ge pcirits.
In addition to ai. at <-<: ph.;i oqi dp}):, ot v/aste discharge
violations .-md tt t vi.^.int effect-^ will materially aid
in follow-up pi u;-t;. c- 'i >-.
2 . Identif ic at _i
The inspection reoot-t <-ic company-1. ng enforcement-
oriented photcxi.ru pi r/ inusjt to rhc- extent practicable
carefully note the:
(a) Subject
(b) Location
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Section VII: Special Consideration^ and Techniques
(c) Points of reference
(d) Photographer's name
(e) Date and time
(f) Type of camera used
(q) Lighting conditions encountered
(h) Focal length of lenses
(i) Type and speed of film
(j) Name of any witnesses
This photographic information is essential to insure
court admissibility.
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SECTION VI31
FEDERAL AND STATE COOPERATION
VIIIA AUTHORITY
Section 402 and 308 of the FWPCA provides for the transfer
of Federal authority, relative to NPDES permits and
compliance monitoring, to the states. Section 308
authorizes the transfer of the monitoring function to the
states without transferring the full NPDES program.
Presumptive of these authorities, Regional Administrators
and some State warf.r pollution i:ontrol agencies have signed
formal agreements or: have entered into formal agreements on
the cooperative monitoring of permittees' effluents.
However, the Act makes i' cit-ar tl«at monitoring of Federal
facilities is essentially a Federal function.
VIIIB OBJECTIVES
Within the framework of tins authority, the objectives of
Federal and State cooperation front the inspector's
standpoint are to ensure that:
1. Information exchange and responsibilities called for
under the cooperative agreements are carried out in a
timely manner.
2, The information gathered is complete arid in an
acceptable form so the agency which has the primary
role in the enforcement of the NPDES permit
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Section VIII; Federal and State Co>peration
requirements is able to use the information in its own
enforcement programs.
3. A successful inspection program is implemented to
ensure a high degree of permittee compliance with
permit conditions, effluent limitations and compliance
schedules.
VIIIC POLICY
The Agency's commitment to ensure full partnership with the
states in field investigations and other NPDES monitoring
activities shall be fostered.
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SECTION IX
SAFETY
IXA GENERAL
The inspection of wastewater end other environmental
pollution control facilities always poses a certain degree
of hazard. The objective of this section is to assure the
safety of inspection arid operating personnel by the use of
proper safety equipment and by the execution of safe
practices.
Inspector* s Responsibility
It is the responsibility of each inspector to:
(1) Be thoroughly familiar with al.l safety guidance and
practices.
(2) Maintain safety equipment in good condition and in
proper working order,
(3) Use safety equipment in accordance with guidance
received, and labeling instructions or as dictated by
common sense.
(H) Guard against body infections by periodically
obtaining typhoid and tetanus innoculations,
IXB SAFETY EQUIPMENT
! Personal Safety Gear
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Section IX: Safety
When performing their inspection duties, inspection
personnel should properly use the following safety
equipment:
(a) Hard hats.
(b) Rubber-soled, non-skid, metal-toed shoes.
(c) Safety glasses (prescription if required),
goggles and face shield.
(d) Gloves: liquid- proof, natural or synthetic
rubber, or throw-away plastic.
(e) Non-skid, metal-toed, rubber boots.
(f) Ear protectors.
(g) Breathing mask or respirator.
2. Safety Equipment
The following safety equipment should be in each
inspector's car for use when needed:
(a) First aid kit.
(b) Fire extinguisher.
(c) Soap, waterless hand cleaner, and towels.
IXC SAFETY PRECAUTIONS
Inspection and Operating Personnel
1. Authority
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Section IX: Safety
Section 20U of the Act requires assurance of adequate
operation and maintenance of wastewater facilities.
Safety is considered to be an integral component of
such assurance since unsafe conditions and practices
adversely affect the operation and maintenance of
wastewater facilities.
2. Inspector's Obligations
The inspector should be on-guard to protect himself
from injury which may result from unsafe conditions or
practices at the wastewater treatment facility. As a
guide in this area all field inspectors should read
Safety in Wastewater Works published by the Water
Pollution Control Federation. This publication
discusses safety precautions necessary for the:
(a) Prevention of physical injuries;
(b) Prevention of body infections;
(c) Prevention of asphyxiation due to lack of oxygen
or presence of noxious gases;
(d) Proper operation of safety equipment; and
(e) Rescue of injured employees.
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SECTION '<
ACCESS AND WARRANTS
XA GENERAL
The Act grants inspectors (including State personnel acting
pursuant to the delegation of authority to the States) the
authority to:
1. Enter a facility or the place where effluent records
are held.
2. Inspect the permittee's monitoring equipment and
techniques.
3. Inspect and copy the permittee's self-monitoring
records.
4. Take samples of discharges which the permittee is
required to sample.
5. Examine any other records which the Administrator
requires to be kept as delineated in Section IV of
this Manual.
All of the above should be done during the normal working
hours observed at the permittee's facility (e.g., office
hours at a steel mill even though operating three shifts)
after presentation of credentials. However, the taking of
composite samples over an extended period to confirm
compliance with a permit limitation will not be considered
contrary to this requirement so long as the sampling
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Section X; Access and Warrants
commences during normal working hours. If initial entry to
the premises of an alleged "midnight dumper" is to be made
after normal working hours, prior instructions from an
enforcement or regional council attorney must be obtained
and followed.
All of these authorities are subject to the "unreasonable
search and seizure" provisions of the Fourth Amendement to
the Constitution. Some of these authorities as well as the
ability to use statements (including supportive documents)
by permittees or their agents, samplers and analysts, may
also be subject to the limitations of the "privilege against
self incrimination" provisions of the Fifth Amendment. This
limitation may occur directly as a result of Federal action,
or indirectly as a result of State action through
interpretation of the "due process" provision of the
Fourteenth Amendment. The applications will be discussed in
the following subsections.
The Act also gives the Administrator or his designee
authority to require a permittee (on a non-routine basis) to
provide other information as may be reasonably required in
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Section X; Access and Warrants
order to determine if the permittee is complying with legal
requirements. The inspector may wish to make use of this
authority as the designee of the Administrator in order to
request information not contained in records which the
permittee is required to maintain under the terms of the
permit. Examples of this type of material are:
1. Changes of processes, products, or volume of
discharge.
2. Treatment processes and the interrelationship of
components.
3. Purchases of equipment, etc.
Since these materials are first being requested "on-site",
the instructions to the inspector on what to do if entry or
information is refused do not apply. The inspector should,
if this material is not forthcoming, continue his
inspection. However, make note of the information or
documents requested but not received so that the same may
thereafter be requested in the form of a Section 308 letter.
XB OBJECTIVES
The objectives of this section are to inform or advise the
inspector of:
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Section X; Access and Warrants
1. The need for obtaining consent prior to entry,
copying, or sampling.
2. The procedures to be followed if consent is not given.
3. The limits imposed on the use of documents or
statements of individuals in criminal or civil penalty
proceedings against them. The self incrimination
provisions apply only to individuals, not to
corporations.
XC UNREASONABLE SEARCH AND SEIZURE
The Fourth Amendment prohibition is not against searches and
seizures, but only those which are unreasonable or to which
valid consent, if required, has not been given. Consent, in
this context, means the intentional foregoing of right to
privacy which is not the result of either fear, ignorance or
trickery. For additional information on unreasonable
searches and seizures consult the current edition of the
U.S. Justice Department booklet entitled "Handbook on the
Law of Search and Seizure."
XD DENIAL OF ENTRY FOR THE REVIEW AND/OR COPY OF RECORDS
If inspectors are not allowed access to the premises to make
an inspection or to perform portions of their inspection
(relating to materials they have a right to examine) after
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Section X: Access and Warrants
presentation of credentials (during working hours), they
should report this fact to their superiors. Before leaving
the facility the inspectors may suggest that the permittee
contact his attorney to obtain the attorney's advice as to
the permittee's responsibility under Section 308 of the Act.
However, the inspector should under no circumstances discuss
potential penalties under Section 309 of the Act, or do
anything which may be construed as threating the permittee.
If required, the inspector's superior will make arrangements
for obtaining a search warrant. Inspectors will work with
an Agency attorney, a representative of the U.S. Attorney's
Office or in a State with primary enforcement
responsibility, a prosecuting attorney, in preparing an
affidavit for a search warrant. Normally the inspectors
will be expected to appear before a U.S. Commissioner or
Judge to confirm that the facts in the affidavit are true.
The execution of the warrant will normally be directed to
the United States Marshall or to the local law enforcement
personnel who will accompany the inspectors to the premises.
XE PRIVILEGE AGAINST SELF INCRIMINATION
The privilege against self incrimination clause of the fifth
amendment to the Constitution prevents the use of
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Section X; Access and Warrants
involuntary confessions or private papers, against a
defendant. Since the privilege does not apply to
corporations or partnerships, and since documents required
to be prepared or maintained by law, such as reports and
records required to be maintained by a dischargers' NPDES
permit are excluded from what is defined as "private
papers", this privilege has irinimal application to
reconnaissance inspections. In those cases where the
discharger is an individual or there is some possibility
that the person from whom information or documents are
sought is a potential criminal defendant, no questions
should be asked, nor any documents other than those called
tor in the permit be requested* (of the potential defendant)
without having first consulted with an enforcement division
attorney or an attorney in the Regional Counsel's office.
*NOTE: Materials designated by asterisks {*) in Appendix B
check lists are those which are not required records under
the regulations or generally specified in permits. See part
XA for procedures to be followed if the materials are not
voluntarily provided.
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SECTION XI
COMPLIANCE EVALUATION INSPECTION REPORT
XIA OBJECTIVE
Clear, accurate reporting is essential to the compliance
Evaluation Inspection operation. It is the basis for
important administrative decisions concerning program
effectiveness, enforcement actions and the proper
programming of future work.
XIB GENERAL
The Compliance Evaluation Inspection Report form replaces
the former Report On Operation And Maintenance Of Wastewater
Treatment Plant by deleting certain data elements and adding
data elements relating to the compliance status of a
permittee.
Due to time constraints in consolidation of operation and
maintenance and compliance evaluation into a single
inspection activity, the compliance Evaluation Inspection
Report form is a physical consolidation of the report forms.
Redundancies have been removed wherever possible but have
not been completely eliminated. (A new and more permanent
form is being developed and will be available in FY 1978.)
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section XI; Compliance Evaluation Inspection Report
The revised form contains a total of 12 pages, consisting of
a cover sheet and Sections A through N. The cover sheet is
a summary of inspection results and is designed to meet
enforcement data needs. The cover sheet should be routed to
the Regional Enforcement Division for review and
determination of compliance status.
For inspection of operational municipal treatment
facilities, the cover sheet plus sections A through M should
be completed. Do not complete part N, page 12 of the form.
Transmit a copy of the municipal operation and maintenance
section of the report to Headquarters in keeping with the
established procedure for an operation and maintenance
inspection. The Headquarters copy should be directed to the
Municipal Operations Branch, Municipal Permits and
Operations Division, Office of Water Program Operations.
For inspection of non-municipal treatment facilities,
complete the cover sheet and sections H through N of the
form. Do not complete sections A through G, the municipal
operation and maintenance section of the report form. Also,
do not transmit a copy of the form to Headquarters,
Municipal Operations Branch. Transmission of non-municipal
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section XI; Compliance Evaluation Inspection Report
inspection reports should be in keeping with procedures
established by the Regions.
XIC PROCEDURES
1. Inspector* s Obligation
Report all compliance Evaluation Inspections by
completing a Compliance Evaluation Inspection Report Form (T-51)
as soon after the inspection as practicable and, if needed, an
Abbreviated Narrative Report (See instructions in this Section).
Copies of narrative reports prepared to support or explain
information included in the Compliance Evaluation Inspection
Report should be attached to each copy of the form. (See sub-
section below regarding the preparation of narrative reports.)
2. Compliance Evaluation Inspection Report
The Compliance Evaluation Inspection Report (See Exhibit B) and,
if needed, a supporting narrative report should be prepared with
a typewriter or legible handwriting.
Complete the numbered captions of the cover sheet as
follows:
A 1*2 Facility Name and Location - Include the legal
name of the facility inspected and the street
name or State route on which it is located.
A 3-5 Countyf Municipality and State - Enter the name
of the county, state and municipality in which
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Section XI; Compliance Evaluation Inspection Report
the facility is located. Municipality means
township, parish, borough, city, etc.
A 6-8 Responsible Official, Title and Telephone No -
Enter the name, title and telephone number of
the person or official responsible for
wastevrater management.
A 9-llFacility Representative, Title and Telephone No.
- Enter the name, title and telephone number of
the person who assisted you during the
inspection, if different from the Responsible
Official.
A12,13NPDES Permit - Enter the number of the NPDES
permit issued for the facility and its
expiration date.
A 1* Basin Code - Enter the code or name of the
drainage basin into which the permittee
discharges.
B 1 Required Action - Enter the current "required
action" from the compliance schedule of the
permit and the two previous "required actions".
E 2 Schedule Date - Enter the completion date for
each of the "required actions" listed in B 1.
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Section XI; Compliance Evaluation Inspection Report
B 3 On Schedule - Indicate by number (l=yes, 2=no,
3=not applicable) whether the "required actions"
are on schedule.
B 4 Remarks - Use this space to indicate why the
"required actions" are not on schedule, use
additional sheets if necessary.
C. Facility Evaluation - Enter the appropriate
number (l=satisfactory, 2=unsatisfactory, 3=not
applicable) to show the status of each listed
phase of the Compliance Evaluation Inspection.
D. Production Rate - Enter the permittee's present
30-day average and daily maximum production
rates, if different from the production rate
specified in the NPDES permit.
E. Effluent Limitations - Enter the effluent
limitations as specified in the NPDES permit.
Also enter the most recent self monitoring data
submitted by the permittee. If the permit
contains effluent limitations for more than a
single discharge, list the effluent limitations
and self-monitoring data for the additional
discharge(s) on a separate sheet and attach to
the report.
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Section XI; Compliance Evaluation Inspection Report
F. Recommendations - Indicate the need for any of
the listed actions.
G. Remarks - Enter any remarks or notes at this
point. If photos were taken during the
inspection, list the identification number of
each photo. Use additional sheets if necessary,
clearly identifying each section or caption
referred to.
3. Municipal Operation and Maintenance Inspection Section
The Municipal Operation and Maintenance Section should
be completed in the field during the evaluation of the
permittee's facility. Complete all applicable
sections of parts A through G that have not been
deleted (gray shading) according to guidance provided
in Instructions For Completion of Report On Operation
And Maintenance of Wastewater Treatment Plants, U.S.
Environmental Protection Agency, Office of Water
Program Operations, March 1974. In addition to
Sections A through G, Section H, Facility And Permit,
Section I, Background of Facility, Section J, Records
and Reports, Section K, Self-Monitoring Program, and
Section M, Permit Verification, must be completed.
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Section XI; Compliance Evaluation Inspection Report
For municipal facilities that are under construction
and have not attained operational status, only the
cover sheet and Section L, Compliance schedules,
should be completed.
H. Non-Municipal Operation and Maintenance Inspection
Section
For a Compliance Evaluation Inspection of a non-
municipal facility, the Operation and Maintenance
Section, Section N, as well as the cover sheet and
Sections H,I,J,K&M, should be completed according to
the guidelines contained in the preceding chapters of
the Manual.
For non-municipal facilities that are under
construction and have not attained operational status,
only the cover sheet and Section L, Compliance
Schedules, should be completed.
XID ABBREVIATED NARRATIVE REPORTS
Abbreviated narrative reports will be used to supplement the
information on the Compliance Evaluation Inspection Report
Form, not to replace it entirely. This report may be used
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section XI: Compliance Evaluation Inspection Report
to explain in more detail the facts and observations
developed during the inspection. Only those details
sufficient to provide a clear picture of the relevant
findings should be included. The inspector should:
1. Be factual and objective.
2. Not present speculative opinions.
3. Not include administrative opinions about possible
regulatory enforcement.
4. Make sure to clearly identify each section or caption
referred to.
5. Sign the report and attach it to Form.
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Sectiqc XI; Compliance Evaluation Inspection Report
viated narrative reports will be used to supplement the
information on the Compliance Evaluation Inspection Report
Form, nS^ to replace it entirely. This report may be used
to explain^in more detail the facts and observations
developed duMng the inspection. Only those details
^Ibt
sufficient to pl^ide a clear picture of the relevant
iBL
findings should be^yicluded. Th^ inspector should:
1. Be factual
Not present specuHltive opinions.
Not include administrative opinions about possible
regulatory enforcement
Make sure to clearly identify each section or caption
referred to.
Sign the report and attach i&, to Form.
jective.
2.
3.
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GLOSSARY
1. ACT - Federal Water Pollution Cent ol Act Amendments
of 1972, P.L. 92-500.
2. ADMINISTRATOR - The Administrator of the Federal
Environmental Protection Agency.
3. AGENCY - The Federal Environmental Protection Agency
(EPA) .
U. BPCTCA - Best Practicable Control Technology
Currently Available.
5. CHECK LIST - Minimum list of items that should be
checked on each inspection to insure the collection
of data for compliance monitoring.
6. COMMON SOURCE POLLUTION - Two or more types of pollution
(Air, Water, Land) from the same source.
7. COMPLIANCE EVALUATION INSPECTION - An inspection conducted
without sampling to determine compliance with Federal
Environmental Pollution Statutes and/or NPDES permit
requirements.
8. COMPLIANCE MONITORING - Collection and evaluation
of data including self-monitoring reports and
self-monitoring verification to show whether
pollutant concentrations and loads contained
in permitted discharges are in compliance with
the limits and conditions specified in the permit.
9. COMPLIANCE SCHEDULE - A schedule of remedial measures
including an enforceable sequence of actions or
operations leading to compliance with an effluent
limitation, other limitation, prohibition or standard.
10. CONFIDENTIAL INFORMATION - Information supplied to the
Agency by a permittee, which if made public would
divulge methods or processes entitled to protection
as trade secrets of such permittee.
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Section XI: Compliance Evaluation Ins action Report
11. INSPECTOR - Any officer or employee of the EPA or
of any State duly authorized by the Administrator
to conduct inspections, make investigations,
collect samples or otherwise carry out the
provisions of the Act.
12. MULTI-MEDIA INSPECTION - The conduct of an
inspection to determine the compliance status
of two or more types of pollution.
13. NPDES - National Pollutant Discharge Elimination
System established under Title IV, Section
402 of the Act.
14. POINT SOURCE - 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, or vessel or other floating craft from which
pollutants are or may be discharged.
15. PROCESS VERIFICATION - Verification that process raw
materials, water usage, waste treatment processes,
production rate, and other factors relative to
quantity and quality of pollutants contained in
discharges are substantially as described in the
permit application and the issued permit.
16. RECORDS AND REPORTS All records and reports maintained
pursuant to Section 308 (a) (A) of the Act and as
specified in the permittees NPDES permit.
17. TREATMENT WORKS - Any facility, method or system for the
storage, treatment, recycling, or reclamation of
municipal sewage or industrial waste of a liquid
nature, including water in combined storm water
and sanitary sewer systems.
NOTE - For definition of technical terms and phases
used in the compliance Evaluation Inspection Manual see the
Glossary Section of EPA Handbook For Monitoring
Industrial Wastewater.
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REFERENCES
1. American Public Health Association, Standard Methods for the
Examination of Water and Wastewater (13th Edition), 1971.
2. American Public Works Association, iunicipal Refuse
Disposal, 1961.
3. Babrock, Russel H., Instrumentation and Control in Water
Supply and Wastewater Disposal, R. H. Donnelley Corp., 1968.
4. Gulp, Russell and Gordon, L. Advanced Wastewater Treatment,
Van Nostrand, Reinhold, Environmental Engineering Series, 1971.
5. Eckenfelder, W.W., Water Quality Engineering For Practicing
Engineers, Barnes & Noble, 1970.
6. Federal Register, Guidelines Establishing Test Procedures
For Analysis of Pollutants, 40CFR Part 136, U.S.E.P.A. Number
199, October 16, 1973.
7. Federal Register, Freedom of Information Act Regulations,
(40CFR2) 1974.
8. Harris, Daniel J. and Keffer, William J.r Wastewater
Sampling Methodologies and Flow Measurement Techniques,
U.S.E.P.A. (EPA 907/9-74-005), 1974.
9. Lung, H.F., Industrial Pollution Control Handbook, McGraw-
Hill Book Co., 1971.
10. State Water Resources Control Board, State of California,
Surveillance and Enforcement Manual, 1974.
11. Texas Water Utilities Association, Manual of Wastewater
Operations, 1971.
12. U.S. Department of Commerce/National Bureau of Standards, A
Guide to Methods and Standards for the Measurement of Water Flow,
Publication 421, May 1975.
13. U.S. Department of the Interior/Bureau of Reclamation, Water
Measurement Manual, 2nd Ed., Denver, Colorado, 1967.
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section XI: Compliance Evaluation Instaction Report
14. U.S. Environmental Protection Agency, Estimating Staffing
for Municipal Wastewater Treatment Facilities, (Contract No. 68-
01-0338). 1973.
15. -, Guidelines For Evaluation of Visible Emissions, (EPA -
340/1-75-007), 1975.
16. -, EPA Visible Emission Inspection Procedures, Stationary
Source Enforcement Division, 1975.
17. -, Field Operations and Enforcement Manual for Air Pollution
Control, Vols. 1,11,6 III. 1973.
18. -, Technology Transfer, Handbook for Analytical Quality
Control in Water and Wastewater Laboratories, June 1972.
19. - Technology Transfer, Handbook for Monitoring Industrial
Wastewater, August, 1973.
20. -, Maintenance Management Systems For Municipal Wastewater
Facilities, (EPA-430/9-74-004), 1973.
21. -, Manual of Methods For Chemical Analysis of_ Water and
Wastes, (EPA-625/6-74-003), 1974.
22. -, Model State Water Monitoring Program, (EPA-440/9-74-002),
1975.
23. -, Operation and Maintenance of Wastewater Treatment
Facilities, 1974.
24. -, Procedural Manual for Evaluating the Performance of
Wastewater Treatment Plants, May, 1972.
25. -, Responsibilities and Conduct for EPA Employees, F.R.,
Vol. 38, No. 73, April 17, 1973.
26. -, Wastewater Treatment Ponds, "Technical Bulletin", (EPA-
430/9-74-011), 1974.
27. U.S. Justice Department, Handbook on the Law of Search and
Seizure, Revised February, 1971.
28. Water Pollution Control Federation, Operation of Wastewater
Treatment Plants, WPCF Manual of Practice No. 11, 1974.
July 1976 Compliance Evaluation Inspection Manual
83
-------
Section XI: Compliance Evaluation Inspection Report
29. Water Pollution Control Federation, Safety In Wastewater
WOrks, WPCF Manual Of Practice No. 1, 1969.
30. Water Pollution Control Federation, Sewage Treatment Plant
Design, WPCF Manual of Practice, No. 8.
31. Water Pollution Control Federation, Sludge Dewatering, WPCF
Manual of Practice No. 20., 1969.
July 1976 Compliance Evaluation Inspection Manual
8«
-------
Section XI: Compliance Evaluation Inspection Report
Section References
Section I
7 & 25
Section II
10 & 14
Section III
3,4,5,12, 20, 24, 26, 28, 30, 31
Section IV
18 & 25
Section V
Section VI
1,6,8,12,13,18,19,22,24,26
Section VII
2,9,12,15,16,17
Section VIII
Section IX
29
Section X
27
Section XI
July 1976 Compliance Evaluation Inspection Manual
85
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF ENFORCEMENT
EXHIBIT A-l
Dear
Pursuant to the authority contained in Section 308 of the Federal
Water Pollution Control Act (33 U.S.C. 1318), representatives of the
Environmental Protection Agency shall conduct, within the next six
months, an inspection of the below named facility to ascertain compliance
with the National Pollutant Discharge Elimination System (NPDES) permit
issued for the facility.
FACILITY PERMIT NO.
Representatives from the Region Surveillance and Analysis
Division will observe the facility's process operations, inspect the moni-
toring and laboratory equipment and analytical methods, collect effluent
samples, examine appropriate records, etc. A single page process and
wastewater flow diagram, or a blueprint of the facility, and production
information should be available for the inspectors at the start of the
inspection.
In order to facilitate access to the plant site, please provide to us,
within fifteen (15) days, the name of an individual at the plant whom we can
contact when we arrive there. Please notify us of any special safety equip-
ment our inspectors should have which you will not be able to provide.
Additionally, please inform the appropriate personnel of the plant about
the forthcoming inspection so that the necessary information will be
readily available and the inspection can be expedited.
If you have any questions relating to this inspection, please call me
at .
Sign
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF ENFORCEMENT
EXHIBIT A-2
Dear
Pursuant to the authority contained in Section 308 of the Federal
Water Pollution Control Act (33 U.S.C. 1318), representatives of the
Environmental Protection Agency shall conduct, within the next six
months, an inspection of the below named facility to ascertain compliance
with the National Pollutant Discharge Elimination System (NPDES) permit
issued for the facility.
FACILITY PERMIT NO.
Representatives from the Region Surveillance and Analysis
Division will observe the facility's process operations, inspect the moni-
toring and laboratory equipment and analytical methods, examine appropriate
records, etc. A single page wastewater flow diagram, or a blueprint of the
facility, should be available for the inspectors at the start of the
inspection.
In order to facilitate access to the plant site, please provide to us,
within fifteen (15) days, the name of an individual at the plant whom we can
contact when we arrive there. Please notify us of any special safety equip-
ment and/or security clearance needed which we must provide or obtain which
you will not be able to provide. Additionally, please inform the appro-
priate personnel of the plant about the forthcoming inspection so that the
necessary information will be readily available and the inspection can be
expedited.
If you have any questions relating to this inspection, please call
me at -------
Sign.
-------
RIN NO. 3500.04 I (T)
A: FACILITY
1. HAM
COMPLIANCE EVALUATION INSPECTION REPORT
DATE
TIKE
am
pm
REGION
2. LOCATION
3. CO:_
B. CUMPLIA'.Ci: SCHUDULE
2--no 3=N.A.
1. RL mired A tion 2. Scl'.odule Date
3. 0:1 t .-hcdule
1. Remarks
I'ACILITi' EV7.LUATI01!
2--Uii'-.at if.factory
( ) ]. Recoids and Reports
( ) >. Op< ratiotis and
Maintenance
( ) ".'. Sa .j'.irj Procedures
( ) 4. flow Mfviiurements ( 5 8. Unauthorized Disc -.arg.
( ) 5. Laboratory Procedures ( ) 9. Other
( ) 6. Eludye Disposal Practices
( ) 7 . AlU 11 .:' r- Power
D- , P.CDVC - If; KATE
." / ?;PI S Perm r
30 Day Averajr
Daily Max.
Current
E. 3 ITLUT ' T
b.
eter
Oil
"£
>H
1. Permit Co:r". i tior.s
7-Ii.i\ Avcrtuji
Co: ic.
ll'G'cU-.
JO-D.V/ A.-.-r .j-
Cone .
i, / , ^
Du ly
;.'ax.
2 . Sol f-'-'oni tor i --7 Dat.-.
/- DL!'/ Av'i acio
Cone.
' :i:;/day
lO-D.iy Average
Coi.r .
1 r,s/«:ay
F. KECO!'. "' :.T<;,TIG!,j
No r -'.'.i'.'n
f"urtr' r info; ma' ion
Improve ')' '1
Mod i f y P' r ' i
Other
i'ol !ov;-up I.C'tter
t.r.forc i-w"it Action
follow-up Inspection
G. IIKKAI
i Y:
Vm.T.D I'.';
cn CKFD F Y
AGf.NCY
DATI:
ENFORCi'! :.'i 'JiVI:~IONS
COMrr,T.V..-T STAVUS
( ) Compliance
( ) Noncon.pl ianco
T'PA Form 1-M (n-7t)
PAGL 1 Oh
-------
. OPERATION AND MAINTENANCE
(Purls A through G to be completed only for
municipal inspections)
DATE OF INSPECTION
RIN NO. 3500.04 I (T)
A. GENERAL INFORMATION
PL ANT
[(a.) NAME
2. TYPfc OP PLANT
(l>.) OWNER
3. PROJECT NO.
"T(r.) 1.0
.OCATIOM
6.
OLLE' 1 ION SYSTEM J7. DATC f'R
CO'.'HINEtl ] -Er-A«ATE 1 j DO TH
4. AVG. DESIGN FLOW
LSI NT PLANT EiEGAN OPERATING
5. DESIGN POPUL AT I ."j
EQUIVAL ENT
8. STATE PERMIT No.
9. IN THE SPAf, PRO', r CD E ELOA, FURNISH A SIMPLIFIED FLO A1 DIAGRAM OR A Wf'ITTEN DESCRIPTION OF THE PLANT UNI 1 :=, IN
FLOW SEQUf '.CE.
DF.H1I' f ' CEIV'1.'". VVATt
11.; ENTITY . -;C!T", , ' S" -(E A'.' ST AN UARDS AN D OR US' - o r ! h f R EC F I VI NG V, A 1 E '.'S
H. CURI-'l ; r I I AMI LOADING
t. AtlN'JAL AV. 1AILY ' l OiV ^ATt
4. ANNUAL AV TOUi, . f R / A '.EnA'ji 'n.f/1)
n r A K I !
t, I'Y . I AIM' ,
6. PRINCIPAL 1 I't S O < N UUST f! A . A ' M f: Dl',' H A I Gl !) 1 d
MUNICIPAL £ jTEM
0. PO.'ULA'ION "QUI V/-L: 141 '.>>; O' INDUS! RIAL WA'..1C1
.10. INFILTHATIL'4 PPOHLEMS
'. ANNUAL AVO KlISF""! Nt)i U ;,Ol in O I- RAW SFWAGE (tiifv'n
/. POPUL AT K)M HQUI VALLN1 r/.<)/)' OF INDUS! RIAL WAS1 :
4. VOLUMF OF INOUS1HIAL W AST LS (n\f d)
PA Form T-51 (9-76)
PAGI ? OF
-------
C. PLANT PERFORMANCE
*
LABORATORY ANALYSIS (Total Platt)
() REPORTING PERIOD
FROM (Month, year)
MONTHLY ITEMS
(b)
(1)
(21
(3)
(4)
I
(6)
(7)
(8)
(9)
(10)
(11)
FLOW frigi/;
(monthly average)
-PEAK FLOW (mf.d)
(maximum day)
SETTLEABLE SOLIDS
(moti thly aver UK c)
INFLUCNT (mlf 1)
EFFLUENT (wl/1)
,:« RGI/OV At. v , f
SUSPENDLD SOLIDS
(monthly avert'tv)
INFLUf-'NT (m,'/ 1)
EFFLU'-NT (m£ ' 1)
^ R6l/" /At,
-------
RIN NO. 3500.04 I (T)
5.
3. fjOl'.S PLAN 1 HAVI. Al TtRNATE ELECTRIC POWER SOURCE'
[ ) OUAL FT I D 1 ] GENERATOR [^ NONE
l IIT PRO OR AM
(n.) HOUTINF MAINTI NANCE SCHEDULES'
(b.) RECORDS OF M Al M T EN AN C E.REP AIRS & REPLCMT
(C.) SPARE PARTS IK VT.N TORY
ADEOU AT ^-
4. ADEQUATT ALARM SYSTEM FOR POWTR OR EQUIPMENT
FAILURES? [ ]VES IT) NO
INADEQUATE
6. IS PLANT EFFLUENT
BEING CHLORINATED'
7. DOES SEWAGE BY-PASS
PLANT IN WETWEATHER
C]YES
8. DOES SEWAGE BY-PASS
PLANT II -pRY
WEATHER'
r]YES rnNO
10. BYPASS FREQUENCY
(Monthly)
9. AGENCIES NOTIFIED OF EACH BYPASS
11. AVG DURATION OF
BYPASS (Hra)
12. REASON FOR BYPASSING
13. CAN BYPASS SEWAGE BE
CHLORINATED? [~] Y Es
14. DO SEWER OVERFLOWS OCCUR
UPSTREAM OFPLANT?
IS. ANY ODOR COMPLAINTS BEYOND PLANT PROPERTY' (II yes, explain)
16. OBSERVED APPEARANCE OF EFFLUENT, RECEIVING STREAM OR DRAINAGE WAY
17. IS A CONSULTING ENGINEER RETAINED OR AVAILABLE FOR CON SU L T ATION ON OPERATING AND MAINTENANCE PROBLEMS'
IJJYES ["] NO (II yes, Check Otic Ol the following) [~"I COM Tl N'-M N G U ASE.5 [~ \ FiCQUCST BASES
18. DO OPERATORS AND OTHER PERSONNEL ROUTINELY ATTEND SHORT
COURSES, SCHOOL OR OTHER TRAINING' f_|YES [*]NO
(n.) If yes, cite course sponsor, and date of last course.
(b.)lfrM, J"< the'r ~nv courses a\allal>!e in this area3
(c.) Is there an est^1'!! sh--d procedure for training new operators-1
19. IS LAB TESTING ADEQUA1 E FOR THE CONTROL
REQUIRED FOR THIS SIZE AND TYPE OF PLANT
AND USES OF RECEIVING WATERS'
Q YES Q]NO (11 No, explain)
2O. EXPLAIN I.'AIN DITFICULTY EXPERIENCED WITH INDUSTRIAL WASTES
21. PERMANTMT RECOf D FILE
i, i.) PLANT OPERATION AND MAINTENANCF. MANUAL' r"|vis , | NO (t>.) AS BU I LT PL ANS AN D SPECI F I C ATI ONS'
c .) MANUF/ CTURFH', OPERATION 6 MAINTENANCE SPKCII 1C ATIONS' [ |YUS [ (NO (d.) F LOW CH A RTS' [ ~] Y E S
~i WEEKL. v >,iAN-Houri <
23. ANNUAL TUDOFT FOR MAINTAINING AND OPERATING PLAtIT
OALAHIfS & 4. AGES 'It EC1RICITV
CIILMIC ALS
M AIN 1 t M A14 C C
STAFMNG & 1 TRAINING OTHER
Sj OTHER I
24. STABILIZATION PONDS
(a.) WEEDS CUT AND VEGETATION GROWTH IN PONDS REMOVED' I (b.) BANKS AND DIKES MAINTAINED' (Krokion. etc.)
NO f.:]vr:s (JJ NO
i.) ANY REPORTS Of GROUND WATER CONTAMINATION FROM POND' (II ye'.v, fil vo lli-tiiils) [ ] Y DS [11 No
(d.)SEEPAGr REPOHTKO'
f-l Y'-s [~1 NO
(p.) ADEQUATE DEPTH CONTROL?
[ 1 Y rs [" ] NO
r EFFLUENT RELEASE IS
["[CONTINUOUS [ "| INTERMIT TEN T
EPA Form T-51 (9-76)
PACT 4 OF 12
-------
D. LABORATORY CONTROL
CODING INSTRUCTION
Enter tost codi s opposite appropriate items. If any of the below tests are used to monitor industrial wastes, pi ace an "X' in
addition to the test code.
1 7 or more per week 3 - I, 2 or 3 per week 5 - 2 or 3 per month 7 - Quarterly 9 - Annually
2 - 4, 5 or 6 per week 4 - as reqjjtred 6 - 1 per month 8 - Semi-Annually
ITEM
RAW
(b.)
&er LUENT
,'/', v,
LIQUOR
FINAL
(c.)
SLUDOE
SUPER-
NATANT
RECEIVING
STREAM
(h.)
2. SUSPENDED SOLIDS
3. SETTLEABLE SOLIDS
4. SUSPENDED VOLATILE
S. DISSOLVED OXYGEN
6. TOT AL SOLI DS
7. VOLATILE SOLIDS
8. pH
B. TEMPERATURE
10. COLIFORM DENSITY
II. RESIDUAL CHLORINE
1?. VOL ATIL E ACIDS
13. M B STABILITY
1*. ALKALINITY
19.
COMMENTS
E. PLANT PERSONNEL INVENTORY
PERSONNEL CLASSIFICATION
(a.)
I. MANAGEM' N T/ SU f F R V ISO R
2. OP 6RATOI,
3. LABORATORY
». M&IN1 EN A'ICE
S. OTHER PL ANT WORKERS
OTHER Of FICE/CL 11RICAL
TOTAL
EMPLOYMlNT
M AM-MOURS
P CR WEEK
NUMBER
tJO, F'l'-
OMNM NDE'li:
,. ^, t ^ __-
(c.) CERTIFICATION
'VOLUM1Aft
NO. RF COM-
M C N D I. D OR
RETQUI RCD
F-1 Y STATE:
ACTUAL.
NO.
CERTIFIED
TRAINING REQUIRED
NEXT 12 MOM THS
(d.)
NEW
HIRES
UPGRADE
(/Yomot/on
or sft/// /m-
piwemenf
EPA Form T-51 (9-76)
PAGE 5 OF 12
-------
[ F. GUIDE VISUAL OBSERVATION - UNIT PROCTSS
1 RATING COUI.S: S S.-ithifnctory; U Unsatisfactory; M Mnrf.ui.-.l, IN In Operation; OUT Out of Operation
I COUDITIOtl OR APPEARANCE
GENERAL
PRELIMINARY
PRIMARY
SPOSAL
G 30Cn~
in
OTHER
SECONDARY-TERTIARY
CHLORINE
GROUNDS
BUIL Ol N G j
POTABLE WATEIR SUPPLY P RO T
SAFETY F EATURCS
BYPASSES
STOP''. WATER OVERFLOWS
MAI NT EN ANCE OF COLLECTION SYSTEMS
PUMP STATION
VENTIL ATION
BAR SCR r. EN
DISPOSAL OF SCFiLIENINGS
COMMIMU TOR
GRIT CHAMBER
DISPOSAL OF GRIT
SETTLING TANKS
SCUM Rl MO V AL
SLUDGE REMOVAL
EFFLUENT
DIGEST c RS
TEMPFR^TUF- A'IDpH
GAS P --^,OUC-"~ '.
HEATI'.C EQU"I.>ENT
SLun&i =UMF;
DRY^:', UEDS
«/ ACUUM FILTT. H
INC IN 1 K ATION
DISPObAL OF SLI.IDGC
FLOW M' TER AND RECORDE R
RECOM5S
LAB C 0 : 1 T RO L ;
fc. F F L U ' NT
CHLORI'J ATORr,
CFFEC1IVE DOSACC
CONT AC T TIME
CONTACT TANK
RATING
COMMENTS
.,
EPA Form T-5I (0-76) PAGr GOT 12
-------
G. NOTATIONS BY EVALUATOR
t. OPERATION AND MAINTENANCE PROBLEMS/ OE FICIENCI KS
CHECK EACH OF THF FOLLOWING ITEMS IN TERMS OF THEIR ESTIMATED ADVE'RSE: AFFECT ON THE PERFORMANCE OF THE PLANT.
ITEM MAJOR
STAFF COMPLEMENT
PERSONNEL TRAINING
OPERATING BUDGET
LABORATORY CONTROL
INSTRUMENTATION
INDUSTRIAL WASTE
PLANT OBSOLESENCE
EQUIPMENT FAILURE
TREATMENT PROCESSES
SLUDGE HANDLING
AND PROCESSING
EQUIPMENT MAINTENANCE
SPARE PARTS INVENTORY
POWER FAILURE
MINOR NONE; . ITEM
OVERLOADS (typo)
H-YDRAULIC
PERIODIC
CONTINUOUS
ORGANIC
PERIODIC
CONTINUOUS
OVERLOAD CAUSE(S):
INFILTRATION
COMBINED SEWERS
INDUSTRIAL GROWTH
RAPID POPULATION GROWTH
INCREASED SERVICE AREA
OTHER:
OTHER:
MAJOR
MINOR
NONE
2. DESCRIBE BRIEFLY THE MAJOR PROBLEMS INDICATED ABOVE (include lollo\v-up actions needed sec instructions)
3. PURPOSE OF INSPECTION 4. GENERAL RATING
[^] GRANT COMPLIANCE
[_ ] PERMIT COMPLIANCE
EVALUATION PERFORMED BY
-
INFORMATION FURNISHED BY
ACCEPTABLE
" " . CONDITIONAL ACCEPTANCE
"--' ' UNACCEPTABLE
TtTLL ' ORGANIZATION
TITLE ORGANIZATION
DATE
DATE
EPA Form T-51 (9-76)
PAGE: 7 OF i;
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RIN NO. 3500.04 I
-------
RIN NO. 3500.04 I (T)
11. Records maintained of major contributing industries using
publicly owned treatment works.
12. Records maintained of major contributing industries' compliance/non
compliance status.
*
13. Quality assurance records kept including spiked samples,
laboratory equipment calibration, etc.
K. SELF-MONITORING PROGRAM
1. Flow Measurement
(__j (1) Primary measuring device (weir, parshall flume, magmeter, etc.)
properly installed.
Type of device
[. I (2) Calibration frequency adequate.
Date of last calibration
L_j (3) Flow measurement records properly maintained.
Method (automatic, manual, etc.)
I I (4)' Primary flow measurement device properly operated and maintained.
LJ (5) Secondary instruments (totalizers, recorders, etc.) properly
operated and maintained.
| _ j (6) Flow measurement equipment adequate to handle expected ranges of
flow rates.
2. Sampling
LJ (1) Locations adequate for representative samples.
LJ (2) Parameters and frequency agree with permit.
LJ (3) Method of sample collection: Manual LJ
Automatic (""]
LJ (4) Sample collection method is adequate.
(5) Water intake sampled and analyzed, if required by permit.
LJ (6) Additional monitoring and analyses being performed more
frequently than required by permit.
LJ (7) When answer to No. 6 is yes, results are being reported in
permittee's Discharge Monitoring Form (EPA No. 3320-1).
LJ (8) When necessary during compositing, samples are properly iced.
I I (9) Proper preservation techniques used.
EPA Form T-51 (9-76) PAGE 9 OF 12
-------
RIN NO. 3500.04KT)
j~~) (10) Flow proportioned samples obtained where required Jay permit.
LJ (11) Sample holding times prior to analyses in conformance with 40
CFR 136.3 regulations.
3. Laboratory Procedures
(1) EPA approved analytical testing procedures used (40 CFR 136.3).
I _ J (2) If alternate analytical procedures are used, proper approval
has been obtained.
| _ I (3) Parameters other than those required by the permit are analyzed.
I _ I (4) Commercial laboratory utilized.
Name _ ^_
Address _ __
LJ (5) Commercial laboratory State certified.
II (6) Satisfactory calibration and maintenance of instruments and
equipment.
II (7) Quality control procedures used.
I _ I (8) Duplicate samples are analyzed. _ % of time.
I ) (9) Spiked samples are used. t _ % of time.
I _ I (10) Laboratory records properly maintained.
I' I (11) Laboratory employees qualified.
L. COMPLIANCE SCHEDULES
( I 1. The permittee has obtained authorization (corporate resolutions,
etc.) to construct the necessary installation.
[ I 2. Proper arrangement har; been made for financing (mortgage
commitments, grants, etc.)
j_J 3. The permittee has obtained the necessary approvals from the
appropriate agencies to begin construction.
{ ( 4. Contracts for engineering .services have been executed.
LJ 5. Design plans and specifications have been completed.
EPA Form T-51 (9.76) PAGE tO OF 12
-------
RIN NO. 3500.04 I (T)
(_J 6. Contract bids have been advertised.
d[] 7. Construction contracts have been executed.
II 8. 'Contracts for labor and materials are in conformance with
permittee's compliance schedule.
L_J 9. Orders have been placed for equipment acquisition.
j_j 10. Construction and/or equipment acquisition is on schedule.
II 11. The permittee or his consultant is monitoring construction
progress.
I I 12. The permittee lias requested an extension of time.
LJ 13. Plant operators are becoming familiar with new elements of the
plant, including equipment.
[ I 14. Appropriate procedures are being used to assure prompt attainment
of operational levels.
ij 15. Self-monitoring procedures have been initiated.
M. PERMIT VERIFICATION
I I 1. Correct name and mailing address of permittee.
I I 2. Facility as described in permit.
I I 3. Principal product or products, and production rates conform
with those set forth in permit application.
I ( 4. Treatment processes as described in permit application.
| I 5. Notification given to EPA/State of new, different or
increased discharges.
I i 6. Accurate records of raw water volume and correct intake
location.
( I 7. Number and location of discharge points as described in permit.
I I 8. Correct name and location of receiving waters.
EPA Form T-51 (9-76) PAGE 11 OF 12
-------
RIN NO. 3500.04 I (T)
N. OPERATION & MAINTENANCE
(To be completed only for non-municipal inspections)
1. Standby power or other equivalent provisions provided.
LJ 2. Adequate alarm system for power or equipment failures
available:
L~j| 3. Reports on alternate source of power sent to EPA/State as
required by permit.
I ] 4. Sludges and solids adequately disposed.
| _ I 5. Any non-permitted discharges.
( _ I 6. Any by-passing since last inspection.
| ] 7. Regulatory agency notified of by-passing.
Dates ,
[ I 8.. Any effluent limitations violations experienced.
|_J 9. All treatment units in service.
f~j 10. Any hydraulic and/or organic overloads experienced.
[__] 11. Treatment facility properly operated and maintained.
j_J 12. Consulting engineer retained or available for consultation on
operation and maintenance problems.
LJ 13. Preventive maintenance records files kept.
(_J 14. Qualified operating staff provided.
{ I 15. Established procedure:; available, for training new operators.
j_J 16. Files maintained on spare parts inventory, major equipment
specifications, and parts and equipment suppliers.
LJ 17. Instructions files kept for operation and maintenance of
each item of major equipment.
EPA Form T-51 (9-76) ' PAGE 12 OF 12
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