ENVIRONMENTAL PROTECTION ACENCY
OFFICE OF ENFORCEMENT
EPA-330/1-78-001
An Overview Of
Pilot Compliance Monitoring
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER, COLORADO
JANUARY 1978
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Environmental Protection Agency
Office of Enforcement
EPA-330/1-78-001
AN OVERVIEW OF PILOT COMPLIANCE MONITORING
January 1978
national Enforcement Investigations Center
Denver, Colorado
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CONTENTS
I INTRODUCTION 1
II SUMMARY & CONCLUSIONS." 3
III STUDY METHODS 6
IV STUDY FINDINGS 8
A. Monitoring Deficiencies 8
B. Additional Information Obtained from PCM Inspections ... 13
C. Manpower Requirements 15
V LEGAL CONSIDERATIONS 17
APPENDICES
A Sample 308 Letter
B Typical Pilot Compliance Monitoring Inspection Report
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I. INTRODUCTION
Section 402 of the Federal Water Pollution Control Act Amendments
of 1972 required the establishment of a National Pollutant Discharge
Elimination System (NPUES) permit program. The permit program is
carried out by EPA or by individual States under EPA auspices. The
permits, which are issued to industrial and municipal point source
dischargers of pollutants, require the permittee to monitor effluents
to verify compliance with the permit's effluent parameters. The self-
monitoring Discharge Monitoring Reports (DMR's) are submitted to the
appropriate regulatory agency, either EPA or the State with NPDES
permit issuing authority. Based on these reports, the regulatory
authority can determine the degree of compliance or non-compliance of
individual permittees.
The EPA has conducted a wide variety of compliance inspections,
ranging from simple "walk-throughs" to resource-intensive "sampling
inspections" which have extended over 30 days with 24-hour compositing
of up to 20 outfalls. As a rule, neither the walk-through nor exten-
sive sampling inspections thoroughly evaluate the permittee's self-
monitoring procedures. Either the permittee is not monitoring while
EPA inspectors are on-site, or sampling inspector workloads preclude
this additional evaluation.
Pilot compliance monitoring (PCM) inspections could be considered
a compromise between walk-throughs and sampling inspections. The
primary objective of PCM inspections was to assess the quality of
self-monitoring data reported by individual permittees. In addition,
process control and operation-and-maintenance procedures were evalu-
ated. Quality control for both field operations and analytical pro-
cedures was reviewed and adherence to construction compliance schedules
was determined.
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In 1976, a cooperative endeavor was initiated between the National
Enforcement Investigations Center (NEIC) and the Water Enforcement
Division - Headquarters Office of Water Enforcement. From January 1976
through October 1977, the NEIC conducted 106 PCM inspections in EPA
Regions I, II, III, V and IX.
This report outlines the procedures followed in the PCM inspec-
tions and summarizes the results and findings.
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II. SUMMARY AND CONCLUSIONS
1. A PCM inspection assesses the quality of self-monitoring data as
well as the permittee's quality control for both field operations
and analytical procedures. Traditionally, these areas of per-
mittee responsibility are not thoroughly evaluated during normal
walk-through or compliance-sampling inspections.
2. The average time required to conduct a PCM inspection, including
clerical work and preliminary preparation, ranged between 9 and
17 work-days with an average of 12 work-days. Of the total,
approximately 75 percent was professional time. The range is
occasioned by the complexity of limitations in the permit and
the adequacy of the permittee's self-monitoring program. By
comparison, a walk-through inspection requires about half this
time, 4 work-days, and possibly less if the subsequent report
is brief; while a full sampling inspection requires an extensive
resource commitment of 25-42 work-days with an average of 32
work-days. Based on the reliability of the information obtained
and the advantage of conducting an on-site quality control exami-
nation, it is concluded that the PCM approach is a more cost
effective use of manpower than either the walk-through or full-
scale sampling inspection for purposes of verifying self-
monitoring data and identifying potential violators in a more
expeditious manner for follow-up with full-scale sampling.
3. Based on PCM inspections conducted by NEIC, the self-monitoring
practices of a majority of NPDES sources are significantly de-
ficient. Most of the sources had major deficiencies in one or
more of the general areas of flow monitoring, sampling techniques
and analytical techniques. Agency use of these data for tracking
permit compliance varies from questionable to unreliable.
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4. At sources where previous inspections had been performed and self-
monitoring deficiencies had been noted, the PCM inspections indi-
cated that these were continuing in number and degree.
5. A major difficulty in completing PCM inspections was the inability
of obtaining, in a timely manner, the results from the permittee
of self-monitoring and performance samples of known value pro-
vided to the permittee for analysis during the investigation. In
some instances, up to three months and numerous phone calls were
required to obtain the data. This in turn had an adverse effect
on trying to expedite responsive reports. The original objective
of a turn-around time of four weeks or less for report transmittal
to the Regions was seldom met for this reason.
6. A field team highly experienced and knowledgeable in the areas of
municipal and industrial process control, sampling, flow monitoring,
treatment technology, operation and maintenance procedures, and
analytical procedures was required to conduct a PCM inspection.
This should be a relatively long-term assignment so that the team
can establish the necessary working relationships. Implementation
of this system would shift skills necessary in Regional S&A Divi-
sions away from the non-professional sampler technicians to
higher graded professionals and thus may require a long lead-in
period.
7. Larger and more complex sources tend to be better prepared to
participate in PCM inspections. These sources also provide more
rapid and technically complete responses with which to complete
reports. However, the smaller, less complex sources can benefit
from PCM since they generally have less exposure to training ir.
proper procedures.
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8. Once the ancillary objective of the PCM inspection is understood
by the permittee, i.e., to improve the accuracy of their pro-
cedures and results, most of them welcome the personal attention
and instruction which accompanies the PCM approach.
9. PCM findings can be used for enforcement purposes, although the
extent of utilization must be made on a case by case basis.
Discrepancies in self-monitoring procedures and techniques cer-
tainly justify the issuance of Administrative Orders to enforce
corrective action. Follow-up inspections could then result in
judicial referrals for demonstrated bad faith or failure to
comply with the Order. Referrals could be made initially in
cases of discovered Compliance Schedule violations or unpermitted
discharges.
10. Although PCM inspections cannot completely replace full-scale
compliance sampling inspections from an enforcement standpoint,
they serve as a cost-effective method of assessing self-monitoring
practices and, therefore, the quality of Discharge Monitoring
Reports. Through application of the PCM method and diligent
follow-up inspections to assure use of prescribed techniques,
self-monitoring data should be capable of yielding a reliable
assessment of those sources which need follow-up enforcement
studies and actions.
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III. STUDY METHODS
EPA presently conducts two types of NPDES inspections, viz, a
simple walk-through, and a full-scale resource-intensive compliance
sampling inspection. The former generally does not include actual
observations of procedures and techniques used by the permittee.
The latter concentrates on the collection of sampling data by EPA
personnel with concomitant high manpower utilization.
The PCM technique relies heavily upon the ability of the EPA
observers to qualitatively evaluate compliance with required pro-
cedures and self-monitoring practices employed by the permittee.
Hence, relatively sophisticated and highly experienced field teams
are required. A team generally consists of a senior engineer, an
experienced chemist and, occasionally, a biologist, microbiologist
or senior technician.
The procedures NEIC followed in conducting the PCM inspections
were as follows:
1. Collect background information and files from the EPA
Regional Office and State on specific permittees.
*
2. Require by 308 letter the permittee to conduct his
NPDES self-monitoring sampling and analyses on a pre-
determined date to coincide with the inspection team's
visit. The permittee is also advised at this time
that verification/performance samples would be pro-
vided for chemical analysis.
See Appendix A for sample 308 letter.
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3. Observe self-monitoring practices including sampling,
flow monitoring and analytical procedure practices as
they were performed by the permittee. Operation and
maintenance procedures were also evaluated. The per-
mittee is requested to transmit results of self-
monitoring verification samples to NEIC as soon as
possible.
4. Advise permittee in the field of self-monitoring dis-
crepancies after the PCM inspection is completed.
The inspection team also advises the permittee of the
proper procedures and techniques to be followed.
5. Follow-up with the permittee after the inspection
with regard to self-monitoring data and verification
/performance samples for the dates of the inspection.
6. Report of evaluation and findings from NEIC to the
EPA Regional Office.
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IV. STUDY FINDINGS
A. MONITORING DEFICIENCIES
Ninety-nine percent (99%) of the 106 sources evaluated under the
PCM had at least one major self-monitoring deficiency. A major defi-
ciency is one which could result in questionable or unreliable DMR
results.
The majority of deficiencies noted were in the areas of inadequate
flow monitoring and accuracy verification, compositing, sample pres-
ervation, sample holding times and analytical techniques. Figure I
shows the frequency of deficiencies noted at the 106 permittees visited.
The following is a narrative summary of the major deficiencies noted
during the PCM inspections.
Flow Monitoring
Flow monitoring ranks very high on the list of problems noted at
the various sources inspected. Below are some of the recurring prob-
lems.
1. Flow-monitoring device improperly installed - The major
problem encountered was that insufficient upstream and
downstream pipe/channel distance had been provided for
location of the sensing device, resulting in excessive
turbulence.
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DEFICIENCY
FIGURE I
FREQUENCY OF DEFICIENCIES
BASED ON 106 PERMITTEES VISITED
(1976 - 1977)
Flow Monitoring:
Inadequate or Absent
Inadequate Accuracy
Checks
Sampling Techniques:
Holding Time
Sampling Technique
including preservation
Compositing Technique
Sampling Point
Wrong Frequency of
Sampling
Analytical Technique:
Performance of Technique
Unrecognized Method
All Analyses not
performed
48%
26%
35%
27%
10%
30%
21%
14%
75%
0 10 20 30 40 50 60 70 80 90 100
FREQUENCY OF DEFICIENCIES (%)
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2. Inappropriate selection of monitoring device type
and/or size - At several installations, the flow-
monitoring device was oversized and unable to
provide an accurate flow signal under existing
wastewater flow rate extremes.
3. Improper or inadequate calibration - The primary
flow-monitoring device was often not properly cali-
brated and hence resulted in an erroneous flow rate
signal. Even if the primary device was accurately
installed and calibrated, the flow recorders and/or
totalizers had often been inaccurately calibrated
or had drifted out of calibration. In general, the
frequency of calibration of flow-monitoring devices
was inadequate.
4. Poor Maintenance - The accuracy of the flow-monitoring
equipment was directly affected by the device's
maintenance. These devices were often found clogged
with debris, sensor elements were coated with
grease, etc.
5. No flow-monitoring devices installed on the wastewater
streams - The frequency with which this problem was
encountered appears to be directly related to the
emphasis that the appropriate control agency placed
upon accurate flow readings. In states where permit
concentration requirements are the primary target of
enforcement, very little emphasis was placed on flow-
monitoring. As a result, numerous flow-monitoring
problems were noted in these States during PCM inspec-
tions.
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Sampling Techniques
Problems related to wastewater sampling techniques were another
major area of deficiency noted during PCM inspections. The following
are some of the problems noted.
1. Sampling locations - Problems with sampling locations
have included sampling at a point where there has been
insufficient upstream mixing of waste streams to ensure
representative samples, sampling an effluent line at a
point upstream of additional contributions to the efflu-
ent, and sampling the influent to the treatment process
downstream of points where plant recycle streams enter
the influent line.
2. Inadequate sampling containers - Repeated problems had
been noted with the use of plastic containers to obtain
oil and grease samples and non-sterilized samplers to
obtain the bacteriological samples.
3. Inadequate sample compositing equipment - In several
instances where automatic 24-hour compositing devices
had been in use, the sampling flow rate was judged
insufficient to guarantee representative suspended
solids sampling. On occasions, time-proportional
samples were collected where flow-proportional com-
posites had been specified.
Sample Preservation and Holding Times
Inadequate emphasis had been placed upon proper sample preserva-
tion and adherence to proper sample holding times. Common problems
were: metals samples not properly acidified; thio-sulfate not placed
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in the bacteriological sample bottles; BOD5 samples not properly refrig-
erated during the sample compositing period and/or during the sample
holding and transport periods; oil and grease samples not acidified,
bacteriological and BOD5 samples not analyzed within the appropriate
sample holding period, and sulfite samples not preserved.
Analytical Deficiencies
In general, NPDES permittees and/or their contract laboratories
used analytical procedures approved by the EPA. This fact alone, how-
ever, did not assure that correct analytical procedures were performed.
Almost without exception, quality control programs at the various lab-
oratories were found to be non-existent. Replicate samples were seldom
performed and the use of standard additions (spiked samples) was rarely
encountered. This situation might be anticipated at the smaller non-
commercial laboratories but should never be encountered at the larger
contract laboratories that are employed to provide accurate data.
Recurring problems had been noted with the use of the orthotolidine
techqniue for chlorine residual and the use of various kit techniques
for metals. Liberties were routinely taken with the BOD,- techniques,
including improper preparation and incubation of dilution water,
improper seeding and improper calculations.
Permit Deficiencies
A significant number of permit deficiencies were discovered during
the PCM inspections.
Permit does not address all of the existing outfalls at
the facility - Outfalls may have been overlooked during
the pernnt preparation and/or piping changes made sub-
sequent to the date of the permit issuance.
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Permit does not address all pertinent parameters for the
wastewaters being discharged - Industrial facilities
change their manufacturing processes and often fail to
inform the regulatory agency that these changes have
affected their wastewaters. Also, in the preparation
of NPDES permits, certain parameters may have been over-
looked for a given facility. In some cases, however,
an excessive number of parameters and/or frequency of
monitoring was included in the permit.
Inappropriate sampling frequency - It was often apparent
during the PCM Inspections that the NPDES permit for a
facility stipulated wastewater monitoring requirements
or other factors which did not accurately define the
variability of the various manufacturing processes con-
tributory to the waste stream discharged. For example,
single monthly grab samples are often stipulated for a
manufacturing process which can change significantly,
not only throughout the month, but daily.
B. ADDITIONAL INFORMATION OBTAINED FROM PCM INSPECTIONS
The PCM inspections yielded valuable information regarding the
quality of generated DMR data. However, additional side benefits were
realized from auxiliary information obtained during these inspections,
which may in the long run be of equal importance to the Agency. Some
of the auxiliary data which were obtained during the inspection are
discussed below.
Evaluation of Facilities' O&M Practices
By talking with the facility personnel and doing a thorough walk-
through of the treatment processes (plus manufacturing operations,
where applicable), it was possible on a one-day inspection to obtain
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a relatively thorough evaluation of potential O&M problems which may
adversely affect the quality of the self-monitoring data. Facility
personnel, particularly those directly involved in the operation of
the treatment processes, were generally willing to discuss such prob-
lems. The NEIC inspectors were often able to glean from these discus-
sions information related to such problems as infiltration and inflow,
industrial waste loads, coordination between the treatment plant per-
sonnel and the manufacturing personnel, etc., as well as to formulate
an opinion as to the general competence of the operating personnel.
From such information, it is often possible to predict whether the
reported DMR data accurately reflected the actual wastewater effluent
characteristics. Also, during the plant walk-through the inspector
was able to evaluate maintenance practices at the facility and predict
whether the treatment processes are susceptible to periodic mechanical
upset.
Evaluation of Facilities' Treatment Plant Design
Some NEIC inspectors spent a considerable amount of time during
each of the PCM inspections evaluating the overall design of the waste
treatment facilities. Design problems ranged in magnitude from the
relatively simplistic (e.g., lack of redundancy on pumping systems,
chemical feed systems, instrumentation loops) to the very significant
problems of over-designed or underdesigned facilities. At one facility
investigated, the current wastewater flow rate was only 12% of the
actual installed design capacity. As a result, the operator had no
operating flexibility. Accurate flow measurements could not be ob-
tained because the flow devices were much too large for the existing
flows. The activated sludge system could not be run in any of the
conventional modes due to the low organic load to the facility. In
effect, a multi-million dollar facility was being operated as an
extended aeration lagoon, the lagoon being, in this case, one of the
concrete aeration basins provided.
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Sludge Handling and Disposal
Another area of concern which was noted repeatedly was that of
sludge handling and ultimate sludge disposal. Several of the instal-
lations visited were designed and constructed with sludge incineration
systems. To date, these sludge incinerators have not been operated
due to the energy shortage. Instead, dewatered raw sludge which was
chemically treated with lime was landfilled.
Evaluation of Contract Laboratorites and Sampling Services
Whenever the PCM inspection teams encountered a situation where
a facility was using a contract laboratory and/or sampling service for
the collection and/or analysis of their self-monitoring samples, the
team chemist and biologist made an inspection of these contract serv-
ices. Some of the laboratories were extremely conscientious and were
found to be using EPA-approved analytical techniques with no apparent
problems. At other laboratories, a complete disregard of approved
analytical procedures was observed.
State certification of the contract laboratories did not appear
to guarantee the quality of the data being generated. Rather, the
quality of the data appeared to be directly tied to the management
orientation of the laboratory. In general, data originating at con-
tract laboratories was as questionable and unreliable as permittee
self-monitoring data.
C. MANPOWER REQUIREMENTS
The following table summarizes the Personnel Investment for the
various types of EPA evaluations. One should note that the PCM in-
spections require more manpower than the simple walk-through, but sub-
stantially less than the resource-intensive compliance sampling
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inspections. This personnel investment includes review of permit files,
Regional Office and State contacts, the inspection itself and the prep-
aration of correspondence and reports (including typing). Only direct
costs have been included.
Pilot Compliance Monitoring Work Days Required/Inspection
Inspection Type Number (Average; (Range)
of Inspections
Work days per Inspection
**
Walk-Through Inspections 4
MEIC PCM Inspections 106 12 9-17
NEIC Compliance Sampling Inspections 16 32 25-42
(Typical Examples)
* Direct costs only
** Region IX estimate
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V. LEGAL CONSIDERATIONS
The primary objective of the PCM program was to determine the
quality of self-monitoring data submitted by permittees under the NPDES
program. The authority to require complete and effective monitoring
is well established in the Federal Water Pollution Control Act Amend-
ments of 1972 (FWPCA) (33 USC 1151 et seq) and its legislative history.*
Section 308(a) of the FWPCA conveys broad authority to the EPA
Administator to require whatever actions are reasonably necessary to
assure compliance with effluent limitations. Section 402(a)(2) auth-
orizes the Administrator to "prescribe conditions for such permits
including conditions on data and information collection, reporting,
and such other requirements as he deems appropriate".
The authority for the Administrator to take reasonable steps to
assure the reliability of compliance and self-monitoring methods used
by the discharger is firm. An actual PCM inspection, as well as re-
quring a permittee through a Section 308 request to perform his
self-monitoring, is well within the Administrator's authority. This
authority extends to requiring permittees to analyze performance/
verification samples for quality assurance of monitoring techniques
and procedures.
A Legislative History of the Water Pollution Control Act
Amendments of 1972 (Committee Print), p. 800 +.
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One must evaluate situations on a case by case basis to determine
the use of PCM data for enforcement purposes. The severity of the
permit violations, as well as the past recalcitrance of the permittee,
must be considered. PCM inspectors found that discrepancies were gen-
erally due to ignorance rather than bad faith attitudes. In these
cases, every effort was made by the inspectors to instruct the per-
mittee in the proper procedures to follow. Even in those cases where
good faith was demonstrated, a Notice of Violation and Order may be
justified requiring compliance in an expeditious manner. This approach
has previously been used by Regional Offices based on NEIC PCM results.
The Order not only required compliance with certain permit conditions
but "certification of compliance" as well. Certified self-monitoring
data has been used as the basis for a referral to the U.S. Attorney.
Notice of Violations and Administrative Orders are not the only
enforcement tools which can be used to follow up on PCM inspections.
Other findings, such as unpermitted discharges or violation of construc-
tion compliance schedules, could easily justify immediate referrals.
In summary, PCM inspections can be used to pursue a wide variety of
enforcement options or identify areas for in-depth studies. At a min-
imum, follow-up evaluations may provide fruitful enforcement alternatives.
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APPENDIX A
SAMPLE 308 LETTER
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APPENDIX A
Date
ABC Company
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 (EPA), specifically of the
National Enforcement Investigations Center, or Region V, may conduct
an inspection of your company's manufacturing operations, together
with associated waste treatment and discharge facilities, within the
next six months. The inspection is designed to carry out EPA's
responsibilities under Section 308. The persons who will be conduct-
ing the inspections will be authorized representatives of the
Environmental Protection Administration as referred to in Section 308
and will present appropriate credentials. They will observe your
process operations, inspect and evaluate your monitoring and field
and laboratory equipment and methods, exarrine monitoring and calibra-
tion records and other appropriate records, and will be concerned
with related matters.
The EPA visit will focus on procedures and, accordingly, it is
requested that company monitoring be conducted under usual practices
and procedures. On-the-spot observations shall be made of sample
collecting, field preservation of samples, handling and transport of
samples and field and analytical equipment used in the actual conduct
of analytical/laboratory procedures. If analyses are conducted by
an outside contractor, EPA personnel will also evaluate analytical
tests and methods as they are being performed. Please inform the
inspectors if any tests are conducted other than at your main manu-
facturing location.
It is requested that plant process flow diagrams, waste treatment
plant flow diagrams, and treatment plant design data be made available
to the inspectors during the first day of their inspection. Also,
the inspectors will desire splits from the company obtained NPDES
compliance monitoring samples. EPA will supply its own sample containers
and preservation, as required.
The EPA inspectors will also provide verification samples for
analytical evaluation by the company for certain pollutant parameters.
The results of these tests, as well as the results of the compliance
monitoring sampling taken during the inspection, should be transmitted
to the EPA's National Enforcement Investigations Center, Denver
Federal Center, P.O. Box 25227, Denver, Colorado 80225, within two
weeks after the EPA inspection.
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Please inform the appropriate plant personnel to expect such
an inspection to insure a rapid plant entry and to insure that these
surveys are conducted without unncessary delay.
We will appreciate your full cooperation in this matter.
Sincerely yours,
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APPENDIX B
TYPICAL PILOT COMPLIANCE MONITORING INSPECTION REPORT
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Environmental Protection Aqency APPENDIX B
Office of Enforcement
COMPLIANCE MONITORING EVALUATION
October 27, 1977
National Enforcement Investigations Center
Denver, Colorado
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INTRODUCTION
On October 27, 1977 personnel from the National Enforcement Investi-
gations Center (NEIC) conducted an MPDES pilot compliance monitoring
inspection at the I The main
purposes of this inspection were to ascertain the quality of the self-
monitoring data reported monthly by the Company to the
^and ultimately to Region USEPA,
and to determine whether the facility was in compliance with the con-
ditions of its NPDES permit. As part of this inspection, the design
adequacy of the Company's wastewater treatment facilities and related
operation and maintenance practices were evaluated to determine what
impact they might have on the self-monitoring data.
A letter sent to the Company by the United States Attorney,
plated September 26, 1977 (copy attached) announced
the intention of the USEPA to conduct this inspection within the next
six months. However, no advanced notice of the specific date of the
inspection was given to the Company.
The inspection consisted of five basic steps: 1) observation of
the sample collection, preservation and transport techniques, 2) visual
evaluation and verification of-the wastewater flow monitoring techniques,
3) critical overview of procedures used in analyzing the samples, 4) a
walk-through inspection of the manufacturing operations and wastewater
treatment facilities, and 5) review of record-keeping procedures, main-
tenance files, and engineering design data.
NEIC personnel left a standard sample for total suspended solids
(TSS) with the Company's laboratory personnel and requested that the
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sample be analyzed and the data results returned to the MEIC within two
weeks. The Company uses the contract laboratory services of Labora-
tories in for analysis of their 5-day Biochemical
Oxygen Demand (BOD,-) samples. To check on the adequacy of company's
sample preservation procedures and to evaluate the accuracy of
analytical techniques, NEIC personnel spiked a portion of the October
26th daily composite sample with a known BOD,- sample and requested that
both the spiked and unspiked samples be analyzed by . NEIC personnel
also visited Laboratories on November 9th and evaluated their
laboratory techniques. In addition, NEIC personnel split with the
Company personnel the daily wastewater composite sample obtained by the
Company at Outfall 001 for October 27, 1977. The split sample was
returned to the NEIC laboratories and analyzed for TSS. The door to the
Company's sampling station at Outfall 001 was secured with an NEIC
padlock during the entire time that the October 27th sample was being
collected to insure the integrity of this sample.
Based on the observations made during this inspection, the data
obtained, and the information reviewed, the inspection form presented
later in this report was completed and conclusions and recommendations
were prepared.
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SUMMARY AND CONCLUSIONS
On October 27, 1977 personnel from the National Enforcement Investi-
gations Center (NEIC) conducted an NPDES pilot compliance monitoring
inspection at the Hastewater
flow monitoring, sampling, and analyzing procedures were observed and
the wastewater treatment facility design, operation, and maintenance
were evaluated. The findings and conclusions from this inspection are
discussed below.
Flow Monitoring
The Company has an 18-inch, standard rectangular weir with end
contractions and a Foxboro Model 40 continuous flow recorder with float
level s-ensor at Outfall 001. The weir is not sharp-crested, but rather
appears to be constructed of angle iron stock. The Company had no
documentation to prove that the weir and flow recorder installation had
been installed and calibrated as a broad crested weir.
Field measurements of depth of flow over the weir (H) were made by
NEIC personnel. Using tabulated data for standard sharpcrested rec-
tangular weirs and the H values obtained, instantaneous flow rate values
- ซ
were determined. These values were compared against the flow recorder
values for the same times. The Company data was approximately 11% lower
than the calculated data at high flow rates and about 36^ lower at an
average flow rate. The differences in flow rates may be attributed to
the fact that the field calculations were made assuming the weir was
sharp-crested (a best available assumption since broad-crested weirs
must be individually calibrated).
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Alternatively, the Company's weir/flow recorder installation may not be
accurate, and the data being generated may not be within the +_ 10%
accuracy range required by the EPA.
Sampling Techniques
The Company obtains daily composite samples of the Outfall 001
effluent with a De Zurik piston type automatic sampler. Due to the
physical construction of this unit, it is not certain whether accurate
suspended solids samples can be obtained through the strainer-type slits
of its inlet. Also, the De Zurik sampler is configured to obtain a flow
proportioned sample based on the depth of flow in the wastewater channel.
The Company's sampler was designed to be used with a sharp-crested
rectangular weir and may not be obtaining a true flow proportioned
sample witM the existing broad-crested weir.
The sample obtained by the De Zurik sampler is not stored under
refrigerated conditions during the compositing period. It is collected
in a metal pot which is exposed to the ambient temperature of the samp-
ling shed. This deviation from EPA standard procedures could signifi-
cantly affect the BOD5 and TSS data obtained from these samples. At
elevated temperatures the samples would tend to degrade and the sample
data would be lower than if proper refrigeration techniques were employed,
Analytical Techniques
A major deficiency noted in the Company's analytical techniques is
that the BOD,, samples are not set-up for incubation within the 6-hour
time period recommended by the EPA. The Company uses the contract
laboratory services of for the
BOD,- analyses. The daily composite BOD,- samples are acidified and
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stored in a refrigerator at the mill. On Mondays and Thursdays they are
sent via commercial parcel delivery service in unrefrigerated containers
to . The Company could not produce any corroborative study data to
indicate that these deviations from standard holding times and preser-
vation procedures do not adversely affect the quality of the BOD5 data
generated. Also, nc or EPA approval of these deviations could be
produced.
Company personnel do not analyze replicate or blank samples during
the TSS tests. They also do not routinely participate in EPA or State
quality assurance programs. Results supplied by Company personnel for
the TSS check sample left with them by the NEIC inspectors were within
acceptable limits. The results of the TSS analyses conducted by both
the Company and the NEIC on the splits of the Company's daily composite
sample for October 27, 197/ were essentially identical. Both the check
sample and split sample results indicate that the Company personnel are
accurately oerforming the TSS analyses.
Analytical procedures used by Laboratories for the BODr
analyses were judged to be acceptable by the NEIC inspectors. A portion
of the October 26, 1977 effluent composite sample was spiked by the NEIC
inspector with a quantity of a quality control check sample, and sent
along with the unspiked sample to for analysis. The data results
returned from the laboratory indicated a 94% recovery of the calculated
spiked value, an acceptable ..result.
Operation and Maintenance
It did not appear during this inspection that the wastewater treat-
ment operations were being optimized, i.e. the visual quality of the
effluent being produced was below that normally anticipated from a
comparable treatment system. Several factors may contribute to this
-------
lack of optimization. Company personnel have had less than six months
experience operating the biological secondary system. There are only
three individuals involved with the operation of the facility and these
individuals must also perform quality control functions for the paper
mill. Maintenance of the weir in the primary clarifier was found to be
sorely lacking. Debris accumulated on the weir and misalignment of the
unit contribute to short circuiting in the clarifier unit and additional
solids loading on the secondary unit. Lastly, certain design decisions
(e.g. final settling tank weir configurations, lack of scum removal from
the secondary plant, return of sludge dewatering centrate directly to
the secondary plant, etc.) appear to present a physical ceiling on the
quality of effluent which can be produced.
NPDES Permit Compliance
The Company's self-monitoring data indicate that since July 1, 1977
when the new permit limitations went into effect there have been no
violations of the average or maximum daily limitations for the permitted
effluent parameters. Daily average values for quantities of total
suspended solids and BOD5 discharged have been 38K to 88% and 11 to 653,
respectively, of the quantities allowed under the permit. The higher
values were associated with the biological plant start-up period. The
plant appears to be stabilizing with time.
As discussed above under Flow Monitoring, Sampling Techniques, and
Analytical Procedures, several deficiencies were noted during this
inspection which can adversely affect the quality of the self-monitoring
data being generated by the Company. Although the Company's self-
monitoring data indicates that the effluent being discharged at Outfall
001 is well within the permit limitations, the accuracy of this data is
suspect and it is therefore not possible to determine the Company's
degree of compliance with the fJPDES permit requirements.
The Company does appear to have met all of the compliance dates
stipulated in the permit.
-------
RECOMMENDATIONS
The following measures are recommended to correct the deficiencies
noted during this inspection:
1. The design and installation of the rectangular weir unit and
flow recording device located at Outfall 001 should be
evaluated. The weir unit as it is currently installed is not
sharp-crested. If it is found that the flow recorder and
composite sampling device being used at this location were
designed to be used with a sharp-crested weir, a new sharp-
crested weir unit should be installed and the flow monitoring
and sampling devices accurately adjusted for the new weir.
2. Once item 1 above is accomplished, a series of tests should be
run to prove that the existing De Zurik sampling device can
" accurately collect total suspended solids samples from the
wastewater channel. Corroborative grab sampling at the weir
discharge could be used for this purpose.
3. The sample collection container should be refrigerated or
iced so that the sample is held at 4ฐC during the compositing
period.
m
4. The BODr sample holding/preservation procedures should be
revised to ensure that the samples are held at 4ฐC during the
time period between when the samples are collected and when
they are set up for incubation. The samples should also be
set up for incubation within 6 hours after they are collected.
These requirements may dictate that the BOD5 analyses be con-
ducted on-site. Alternatively, tests should be conducted to
prove that the current BOD,- sample holding/preservation pro-
cedures yield accurate data.
-------
8
It should be noted that the Company personnel stated during this
inspection that the has given their approval to the non-refrigerated
sample collection technique and the current methods of holding/preserving
the BODj- samples prior to analyses referred to in items 3 and 4 above.
However, no documentation could be produced to substantiate this claim.
Although not specifically required by the NPDES permit, it is
further recommended that a laboratory quality control program be im-
plemented including the analysis of replicate total suspended solids
samples and the use of blanks in these analyses. Routine participation
in EPA and/or State check sample programs is also recommended.
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COMPLIANCE MONITORING EVALUATION REPORT
Date:
Time 7 : 1
Region
,-ACILlTY
NAME
LOCATION
COUNTY
MUNICIPALITY
STATE
Responsible Official
Title
Telephone No.
NPDES Permit No.
Permit Expiration Date
\
Receiving Stream
Inspection Attendees
Affiliation
Hi Hi am Abbott
David Brooman
USEPA-MEIC
USEPA-NEIC
Type of Facility and General Process Description
The Company manufactures about tons/day of paper napkins from
reclaimed fiber. There are paper machines
at this mill, one a ton/day machine and the othtr a ton/day
unit. Only the ton/day unit was operating during this inspection.
The larger machine was down for scheduled maintenance.
The majority of the pulp used at this mill is manufactured by de-
inking printed broke. Pulp produced from the broke undergoes
several washing, screening, and bleaching operations before being
used as feed to the paper machines. Polyethylene fiber material
removed in the broke/pulp deinking and screening processes are used
as supplemental fuels in the Company's boilers.
#
The Company has instituted an extensive water recycle/reuse program
at the mill to decrease the volume of wastewaters being discharged
from the facility. The reuse program is discussed elsewhere in
this report.
FACILITY
( 1)
(2 )
(4 )
1.
2.
3.
EVALUATION
Records and Reports
Operations and
Maintenance
Samoling Procedures
1 = Satisfactory 3 = N.A.
2 = Unsatisfactory 4 = Undetermined
(4)
( I5
4.
5.
6.
7.
Flow Measurements
Laboratory Procedures
Sludge Disposal Practices
Alternate Power
(1)8. Unathorized Discharge
(3)9. Other
-------
NPDES Permit Monitoring Requirements (Effective
Outfall
No.
Source of
Wastewater
Parameter
Limitations
Quantity
Jay
kg/day.'(Ib/day)
Quantity
Concentration
Avq. Day Max. Day Avg. Day
* ko/clay (Ib/day) mq/i
Monitoring
Frequency
Sample
Tyoe
001
Effluent from BOD5
wastewater
treatment TSS
facility
serving pH
paper makipg
operations' Flow
250(550) 500(1100)
300(660) 600(1320)
(6.0 to 9.0 units
range)
Daily 24 hr.Composi
Daily 24 hr.Composi
Daily Grab
__*
*
* - The permit does not specify a monitoring frequency or procedure for flow
after However, the permit conditions prior to this
date were for continuous flow monitoring. Apparently, this discrepancy
was due to a typographical error. The company does have contiuous flow
monitoring equipment.
-------
11
Description of Uastev/ater Treatment Facilities:
Since the early 1970's the Company has been involved in a program
designed to maximize recycle/reuse of wastewaters generated in the
deinking, pulp preparation and paper machine operations, and thus reduce
the amount of wastewaters which are ultimately discharged from the mill.
Initial stages of this program concerned the segregation of the deinking
and paper mill wastewaters. Additional screening equipment was installed
to allow the segregated deinking wastewaters to be chemically treated,
settled in a 70 ft. diameter clarifier, and essentially totally recycled
in the process. White water from the paper machines are re-used exten-
sively as dilution waters for the broke pulp, in the paper machine
showers, and as make-up water elsewhere in the processes. The Company
has been successful in significantly reducing the wastewaters discharged
from the mill. Currently, only 60-70% of the pre-closeup wastewater
volume is being discnarged.
Excessive white water produced at the paper machines which cannot
be recycled and other miscellaneous wastewaters produced in the processes
are discharged to the Company's wastewater treatment facility which is
shown schematically in Figure 1.
The wastewaters are pumped from the mill and first enter a 40 ft.
diameter primary treatment clarifier unit. Polyelectrolyte is added to
the wastewater at the influent well of this clarifier to aid in the
precipitation of solid materials. Sludge accumulated in the clarifier
can be handled in two alternate manners. It can be pumped directly to
the 70 ft. diameter clarifier mentioned above, collected and thickened
in this unit and then pumped along with the 70 ft. clarifier sludge to
the sludge dewatering facilities discussed later. This is the normal
operating mode. In the alternate mode, sludges from the 40 ft. and 70
ft. clarifiers are pumped directly to the sludge dewatering facilities.
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12
Effluent from the 40 ft. clarifier is routed to the first stage of
a two-stage activated sludge system. The wastev/ater is
combined with the first stage return sludge and aerated in an 8000
gallon aeration tank for approximately 1.4 hours. Nutrients in the form
of gaseous ammonia and phosphoric acid are added to the primary clarifier
effluent to maintain a BOD:M:P ratio of 100:3.0:0.5. The first stage
unit's aeration system is operated so as to maintain a dissolved oxygen
concentration in the mixed liquor of 0.5 to 1.0 mg/1 and, hence, promote
the growth of bacteria in this stage.
The mixed liquor from the first stage aeration enters a 163,000
gallon capacity, rectangular settling tank through a common-wall diffuser.
Sludge is removed from the tank by siphon pipes supported on a bridge
mechanism which traverses the length of tl.e tank. The sludge is trans-
ported by a channel to a sump. From here it is recycled by airlift
pumps to the first stage aeration basin (return sludge) or wasted and
combined with sludge from the 70 ft. diameter clarifier for final sludge
dewatering. Scum which accumulates in the settling tank is skimmed by
mechanisms on the traveling bridge, collected and introduced back into
the return sludge channel mentioned above. There is np_ discrete scum
collection/disposal system.
Effluent from the first stage settling tank is collected in two
sets of double in-board weirs which traverse the length of the tank
parallel to the direction of.flow. The first stage effluent is fed
to the second stage biological unit. This stage is essentially identical
in design to the first stage with the only minor differences being in
unit volumes and the following operational parameters. The dissolved
oxygen concentration in this stage is maintained at 2.0-3.0 mg/1. The
higher dissolved oxygen level plus a reduced BOD5 loading rate' promotes
the growth of protozoa in this stage. Sludge wasted from the second
stage is returned to the first stage aeration unit.
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13
The effluent collection weirs on the second stage settling tank are
identical to those of the first stage. The weir design appears to
encourage short circuiting of solids to the tank effluent. This short
circuiting is less critical in the first stage since it is followed by
the second stage units. However, any solids lost due to short circuiting
in the second stage are discharged directly to the receiving waters.
The effluent from the second stage settling tank flows by gravity
to the Company's effluent sampling and flow monitoring station at Outfall
001 and then a short distance later is discharged directly into
. Backwash water from the Company's process water filtration
plant is combined with the treated wastewater just prior to the sampling
station.
Sludge dewatering equipment at the facility consists of two centri-
fuges operated in parallel. Feed to the centrifuges can be Combined
sludges from the 70 ft. and 40 ft. clarifiers plus waste activated
sludge -from the biological systems (normal mode) or separated sludges
from the 70 ft. and 40 ft. clarifiers plus the waste activated sludges
(alternate mode). In the normal mode, the centrate from the centrifuges
is routed to the effluent launder of the 40 ft. clarifier and then
directly to the unit. In the alternate mode the centrate
is routed to the influent well of the 40 ft. clarifier and receives
primary treatment. Sludge cake produced by the centrifuges is hauled to
a Company owned landfill where it is buried.
* *
The Company is currently reworking an existing earthen basin located
between the mill and . The reworked basin will have an
impervious clay liner and will be used as an emergency spill basin. The
mill proper has no back-up electrical power system; hence, the pumps
which transport wastewater to the treatment plant and recycle much of
the process water would be inoperable during a mill power outage. In
this event, wastewaters resulting from basement flooding would be
-------
diverted by gravity to the emergency spill basin. The contents of the
70 ft. clarifier would also be diverted to this basin whenever the
clarifier is taken out of service for major maintenance. There will be
no direct discharge from the emergency basin to ' The basin
contents will be pumped to the head of the treatment system's primary
unit using portable pumping equipment.
-------
15
f.r.0 e,
ฃ. **.
40-ii 7> rrimars.1
Clo..-.{.'sr '
'hosT)hor/c nc'\a
no1 fimmom'o. ^
*
-^\ '
\ i y
- j^
/\ -s'^g
- ซ Y on
r
1
1.
ฃ
13
15
JhjT--
A Ri; i
. |
1
n 1
[*"
1
1
i
i
u*.
-r-
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i
i >JT n j
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A i^'asreo ,
Activate 5 Isifl^f.
i LE^EUC
7&Sdc
e Cake Vo La
)
1 x^. J. r
....'...j
5&i1Uoc>
s
A.I-I!
r
nero.Ton
Se-fff.oo
f
1 1 1 1 1
1
1 1 1 1 1
__,5J
ซ
L
3
Irt
. 8
<ฃ
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Figure 1 003.
^Simplified Wastewater Treatment Diagram
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16
Average Treated Wastewater Flow of Facility? Approximately 1.0 MGD
Average Design Flow of Mastewater Treatment Facility: 1 0 MGD
Alternate Electric Power Source /XX/ Dual Feed / / Generator / / None
~7 Other (Explain):
Adequate Alarm System for Power or Equipment Failures? . T7 Yes /~~7 No
If no, explain:
Observed Appearance of Effluent, Receiving Stream or Drainage '-fay:
The effluent at Outfall 001 was milky white, quite turbid and
ocassionally had large paper solids in it.
The effluent plume discolored the receiving waters for a considerable
distance.
Consulting .Engineer Retained or Available for Consultation on Operating
and Maintenance Problems? /j~> Yes r. No
If yes, who?
Are lagoons Used in Treatment Process? /%. Yes /__t No
If yes, what is treatment function? j|ie Company has an emergency holding
lagoon which can be used to collect excessive spills in the mill basement,
used for clean-out of treatment facility units, etc.
*
Are lagoons lined? /ฃ/ Yes ฃ7 No If yes> wnat material?
The lagoon will be clay lined
Condition of Ifmnq?
The lagoon was still under construction
Condition of dikes?
Still under construction.
Any seepaae evident? / / Yes -'x/ No
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17
NOTATION'S BY EVALUATOH
OPERATIC1! I'iO MAINTENANCE PRODLEI-'S' 2EFICICNCIES
I C"EC" ; VO" OF TซE FOLLOWING ITE'IS IN TEPWS OF TnCIR ESTIMATED ADVERSE AFFECT ON THE PERFORMANCE OP !*?. DLI-IT
4AJOR uiN =
S'AFF
OVERLOADS 'fvpe>
EL TRAINING
MVDR
TC3 f CO'JT=OL
CONTINUOUS
l'i3L5"-| AI. n 1STE
N.A.
PERIODIC
C3SOLESENCE
CONTINUOUS
OVERLOAD C AUSE(S)
Unit underdesignecT
THEATWENT PROCESSES
HปNO1_ING
AMD PROCESSING
nd/or mill water recycle
program has not been
ECUIPMEN" MAINTENANCE
maximized
SDAPE -J
INVESTOR"
POWER
OTHER
Treatment Plant Design
DESCRIBE EBRIEFLY THE MAJOR PROBLEMS INDICATED ABOVE
1. Staff Complement: The wastewater treatment staff is also responsible
for product: quality control functions in the mill. It did not appear
during this inspection that the existing 3 man staff can adequately
perform both functions.
2. Laboratory Control: Problsms were noted with the Company's sample
preservation and handling procedures as discussed elsewhere in this report.
3. Instrumentation: I-rob!ems were noted with the weir installation at
Outfall 001 as discussad elsewhere in this report.
4. Equipment Maintenance: Problems were noted with maintenance of the
primary-clarifier unit as discussed later in this report.
5. Hydraulic Overloads: The primary clarifier is underdesigned for the
existing f]ow rates.
6. Treatment Plant Design: The weirs on the final clarifiers of the
biological system encourage unit short circuiting due
to their orientation and location. Also, there is no way to physically
remove scum from the biological system. Scum which is collected from
the final clarifiers is returned to the aeration system in the
return sludge stream.
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13
SELF-MONITORING PROGRAM
On the following items, code 1 = yes, 2 = no, 3 = undetermined,
4 = not appl icable.
RECORDS AND REPORTS
T" 1. Prooerly maintained records of date, exact place and time of
samplina.
ฃ\J 2. Properly maintained records of the dates samples were analyzed.
/7T 3. Prooerly maintained records of who performed the analyses.
/|7 4. Properly maintained records of the analytical techniques and
methods used.
'y 5. Properly maintained records of the results of analyses.
/' 6. Records maintained for a minimum of three years including all
original strip chart recordings (continuous monitoring instru-
mentation calibration, maintenance records).
.'77 T P'ant operating records kept including operating logs of each
treatment unit.
/]7 8. Risults of samole analyses correctly calculated and recorded.
/_']/ 9. Self-monitoring frequency and oarameters conform to permit
requirements.
/T7 10- Laboratory records consistent with DMR data.
/' cJ 11. Records maintained of major contributina industries usinq
publicly owned treatment works.
/_ฃ/' 12. Records maintained of major contributing industries' compliance/
non-compliance status."
(_\J 13. Quality assurance records kept including spiked samples, laboratory
equipment calibration, etc.
Other Comments on Records and Reports:
-------
19
rLO'-.' MEASUREMENT NOTE: l=Yes, 2=Mo, 3=Undetermined, 4=Mot applicable
/T 1- Primary measurina device (weir, parshall flume, magmeter, etc.)
properly installed.
Type of device See note below
_j~ 2. Calibration frequency adequate.
Date of last calibration Monthly
1 3. Flow measurement records properly maintained.
Method (automatic, manual, etc.) Automatic
/_3 4. Primary flow measurement device properly operated and maintained.
/ .1 5. Secondary instruments (totalizers, records, etc.) properly
operated and maintained.
//~3 5. Flow measurement equipment adequate to handle expected ranqes of
flow rates.
Other Comments on Flow Measurement:
The Company monitors effluent flow at Outfall 001 with an 18"
standard suppressed rectangular weir installation. Depth of flow
over the weir is measured by a float in a stilling well connected to
a Foxboro Model 40 flow recorder. The problems with the insta'lauion
are that the weir is not she^p crested and the approach velocity in the
weir channel appears to be excessive. The weir plate appeared to be
constructed out of angle iron stock. The weir crest measured approxi-
mately-?". The Company had no documentation to indicate that the weir
had been installed and calibrated as a broad crested unit.
Field measurements made by the NEIC inspection team indicated that
the flow recorder unit read approximately 11% low at about 1200gpm and
36% low at about SOOgpm. These flow rates were the maximum and average
values respectively experienced on this day. The field calculations were
made assuming the weir was sharp crested.
SAMPLING
/1~ 1. Locations adequate for representative samples.
/T 2. Parameters and frequency agree with permit.
/ i' 3. Method of sample collection: Manual !
Automatic
/_j 4. Samole collection method is adequate. See note 1 on next page.
/ 4 5. Water intake sampled and analyzed, if required by permit.
6. Additional monitoring and analyses beina performed more
frequently than required by permit.
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20
1 = Yes, 2 = No, 3 = Undetermined, 4 = Not applicable
T" 7. '-Ihen answer to No. 6 is yes, results are he inn reported in
permittee's Discharge Monitorinci Form (F.PA Mo. 3320-1).
' ? 8. When necessary during compos itinri, samples are prooerly iced.
. 2' q. Proper preservation techniques used. See Note 2 below
_ 3 10. Flow pronortioned samples obtained where required by permit.
_ See Note 1 below.
__2 11. Sample holdina times prior to analyses in conformance with dQ
CFR 136.3 regulations. See note 3 below.
Other Comments on Sampling Techniques:
l)The Company uses a DeZurik Automatic Sampler and Flow Meter, Model
SN34460, to obtain a 24-hour composite sample from behind the weir
at Outfall 001. The sampler has a series of vertical slits immersed
in the wastewater stream through which the sample enters the unit.
These slits may act as a strainer thus preventing the unit from obtain-
ing a representative TSS sample. The DeZurik sampler has a physical
configuration which permits it to obtain a flow proportioned sample,
based on the depth of flow in the wastewater channel. The Company's
unit was designed to be used with a sharp-crested rectangular weir and
may not be obtaining a true flow proportioned sample with the broad-
crested weir actually installed at Outfall 001. 2)The composite sample
is not refrigerated during the compositing period. It "is stored at the
ambient temoerature of the sampling shed. 3)The BODr samples which are sent
tc a contract Uuoratory for analysis are not analyzed within the 6-hour
holding time recommended by the EPA.
LABORATORY PROCEDURES:
/_2/ 1.. EPA approved analytical testing orocedures used (40 CFR 136.3).
/ฃ/ 2. If alternate analytical procedures are used, proper approval
has been obtained.
3. Parameters other than those required by the permit are analyzed.
7 4. Commercial laboratory utilized.
(For BODj. analysis only) Name
_
Address_
5. Commercial laboratory State certified.
*
6. Satisfactory calibration and maintenance of instruments and
equipment.
7. Quality control procedures used, see note 1 on next page
/2/ 8. Duplicate samples are analyzed. _ % of time.
See flote 1 .
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21
1 = Yes, 2 = No, 3 = Undetermined, 4 = Not applicable
/2 ' 9. Spiked samples are used. % of time.
^_]_ 10. Laboratory records properly maintained.
,_L 11. Laboratory employees qualified.
General Comments on Laboratory Procedures:
1. Company personnel do not run duplicate and blank TSS analyses.
These quality control procedures should be implemented.
2. If the Company opts to run BODr analyses at the plant rather
than send them to a contract laboratory, a quality control program
should be established for these analyses also.
3. All analytical procedures observed at the Laboratories
appeared to be satisfactory.
Results of MEIC Quality Control Check Samples Analyzed by Laboratory
The company reported a value of 42 mg/1 TSS (true value 51 mg/1)
on a check sample supplied by inspection team. The value obtained
is acceptable.
A portion of the effluent composite dated 10/26/77 was spiked with
10ml of a quality control check sample (5840 mg/1 as a concentrate)
and delivered to Labs along with the unspiked composite. Results
yielded 94% recovery, which is acceptable.
Results of Company-EPA MEIC Split Sample Analyses:
The effluent
composite of 10/27/77 was split and analyzed for TSS by both EPA and
Company personnel. The EPA result was 40 mg/1; the Company value was
42mg/l. These values are essentially identical.
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22
1 = Yes, 2 = No, 3 = Undetermined, 4 = Not applicable
OPERATION AND MAINTENANCE
1. Standby power or other equivalent provisions provided.
?. Adequate alarm system for power or equipment failures available.
3. Reoorts on alternate source of power sent to EPA/State as
required by permit.
'~ 4. Sludges and solids adequately disposed. Sludge disposal site
was not observed.
2' 5. Any non-permitted discharges.
.'~2 6. Any by-passing since last inspection.
_jf 7. Regulatory agency notified of by-passing.
Dates
8. Any effluent limitations violations experienced.
,~ 9. All treatment units in service.
/?/ 10. Any hydraulic and/or organic overloads experienced.
_2,. 11. Treatment facility properly operated and maintained. See notes below
12. Consulting engineer retained or available for consultation on
. operation and maintenance problems.
13. Preventive maintenance records files kept.
14. Qualified operating staff provided.
_2.' 15. Established procedures available for training new operators.
ฃ_]_ 16. Files maintained on spare parts inventory, major equipment
specifications, and parts and equipment suppliers.
1. 17. Instructions files kept for operation and maintenance of each
item of major equipment.
Other Comments on Operation and Maintenance
It was apparent during this inspection that the wastewater treatment
system was not being operated in an optimal mode and that proper main-
tenance was not being administered to the treatment equipment. These
judgements are based on the observed quality of the effluent being
produced as well as visual observations of the treatment processes
and general housekeeping in the treatment plant area. Specific points
noted include: 1) The 40 ft. diameter primary clarifier's effluent
was very turbid and appeared to contribute an inordinate TSS load
to the secondary treatment units. The primary clarifier unit is
-------
23
1 = Yes, 2 = No, 3 = Undetermined, 4 = Mot applicable
obviously hydraulically overloaded. However, the effluent weirs were
badly out of level and clogged with debris and obviously contributed
to short circuiting in the clarifier. 2) Although the Company is
reportedly using polyelectrolytes to improve the solids removal in the
primary clarifier, there was no evidence that jar tests are routinely
run to optimize polyelectrolyte addition rate. Also, the poly-
electrolyte is added directly to the influent well of the clarifier.
It is doubtful whether optimum mixing of the polyelectrolyte and waste-
water occurs at this location. 3) The centrate from the sludge de-
watering processes are introduced directly into the primary clarifier
effluent launder. Any solids contained in this centrate are there-
fore passed on directly to the secondary treatment units. 4) General
housekeeping at the treatment facility was poor. Of particular note
were the sludge dewatering and sludge handling facilities.
It appears as though the majority of the operations and maintenance
problems noted are directly related to an inadequately sized waste-
water treatment staff as discussed elsewhere in this report.
PERMIT VERIFICATION
JjL 1. Correct name and mailing address of permittee.
/4~7 2. Facility as described ir permit.
Jj~ 3. Principal product or products, and production rates conform
with those set forth in permit application.
/ V 4. Treatment processes as described in permit application.
5. Notification given to EPA/State of new, different or increased
discharges.
6. Accurate records of raw water volume and correct intake
location.
7. Number and location of discharge points as described in permit.
8. Correct name and location of receiving waters.
-------
-t.lii g* i.iU'i .- 'i j ,'i .. I'.lil iu ,/;
UNIT!1.!) STA'lTV t'iM'Oiซป- I
Sepucnbcr .io, 3977
D&ar Mr.
Fursu-unt tc the authority contained in Sec Lion 308 of the YcdersL
V.'atsr Pollution Control Act (33 U.S.C. ง1318), representatives of me
En7iror.:".2iical Prorec'.ijn Agency (EPA), specifically cf. tha National
Enforce.!1 ei.t Investigation Center, or.Region , r.ay conduct an inspection
of yc-_r company's r'anufacLurins; operations cogethsr with ?.ssoci;ited
waste-- CL'catTisni: aad discharge facilities within the ncKi sis r.cnths.
The inspecLion-:s designed to carry or.t EPA's responsibilities 'inder
Scctdon 308. The persons i;ho will be conducting the inspections will
be authorised representatives of the Environmental Frotcctior. Agency as
rcfcvrnd to in Section 308 and will present, appropriate credentials.
They will observe your process operations, inspect and evaluate your
monitorii-s and field and laboratory ccuj.p;ncnt ar.c. ncthciib, exar.sj.re
monitoring and calibration records', and other appropriate records and
will be concerned with related natters.
The EPA visit will focus on piocodur^r. and, accordincly, it in
requested "-.hat company monitoring be ronductec under usual practices
Hid proc-C'hires. APOHR other cliLnf.R^ on-thc-spor obr.erv.-iticr.s s!1"!! he
made of Suir.plo collcctipj, field preservation of .samples, linsiJling and
truiisuort of samples, and field and analytical equipment u:,rd in t'.ic
actual cunJncr. of analytiral/l.'iiiornCoLy procciluron. If anclysot: arc
conilyctrJ by an outside contractor, Kl'A pcr&onncl will also o.vaJuati!
r.n.'ilyt Lea i Lc:tts .1:11! r...;i:hudH as they .ire hi: l\iy, purfuriiicd. Please inform
th<: in^pucfor1: if any tests are conducted other thaa at your rain
mnnuCac11!ri rig iocation.
-------
YC.T
Weekly Averages
1-7
F-l '
?-ป!
5-
'- 1
ซ.,
>^>
,*-*',
' 5 i~V
/f
9
9
;*
/'/
/.'/
'
7 2
A ^
7 /
/ ,
7 ^
? '/
7-7
.3 *
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'
Jo/
3v,r
t/'^1
'
w
'c^
Of
-?-\
(0 Tc-,) cf ;r.-b sa-.plc .it tinv oT -,j, iilui;;
(3) C!:iซis Clccf.odc net>od
(3) Cl.T.s Fiber riliratio:i pro
(I) Diluticn net hod
rcrfor.-cd by
-------
Month -5e ^7 - 77 YCT
o
JT
n
o
r;
1
2
^
4
5
i,
7
8
9
3
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Analyst
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Remarks
/ซ A,.* CX. _'(.- f - r.
r..si ...
-,-,. ซ., J - . -_
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1
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>rซ0 i-l.' ' T. 1 l'.i P
r i
Tc~p of .^I'in ssnplc ,ir l
(2) Cljss Electrode rctl-nU
(3) Class Fiber Filtration pi
('.) L>: lution nct!,od
1'crroT-eil by
-------
Montli
U s
77Ycr
C.
O
c
in
0
n
in
C.
o -
0 ซ-
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in
B
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10
Suspcndcd So
Suspended So
hsdnv
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a.
c.
a
o
a
Remarks
'i-i
/7
I 7.^
7.U
7
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1 7
31 I 7.
7"-'
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17
7,7
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7,7
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7.7
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10
c
7.6
10,1(1131
11
21 7.6
7.5 177 TS
12
15
17
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15
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16
17
f-ini.OILl I H I
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131
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32'
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7 f.
19
-> 11.473
7.\
IP --i
J. '
20
7-3
7.5
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21 I/*J2 11.613
22
23
n,?
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7,1
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24
25
25
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17
PA
7.1
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29
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30
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7?
j'y
37
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Weekly
7.V
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1-7
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7,-"
,->; |.-^-^
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;-
i,>^).
f,^j
(1) TCT?.
(2) Cl.is-,
(3) Class
/ ,.->'/
' f-'f
1 }37\
ft
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/I*
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7,
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v i"
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7 7
V/,
* 9 J 7 *
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/ 0
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J.?
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7- *
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3fj;
?3f
cf ฃr:ib srr.plc iir ti.ic of s.i~plin.".
Elcctioc.^ S'crhod
Fib?r Filtration procedure
(4] Dilution rcthod
Pcrforrsd by
------- |