ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORH1FNT
Audit Inspections
of
Wastewater Sonn
ONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER, COLORADO
AUGUST ?q
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/1-79-004
PERFORMANCE AUDIT INSPECTIONS OF WASTEWATER SOURCES
August 1979
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
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CONTENTS
I INTRODUCTION 1
II BACKGROUND REVIEW 3
III NOTIFICATION AND ENTRY 5
IV FACILITY INSPECTION 7
V FOLLOWUP ACTION 11
APPENDICES
A SAMPLE 308 LETTER
B TYPICAL PILOT COMPLIANCE MONITORING
INSPECTION REPORT
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I. INTRODUCTION
Section 402 of the 1972 amendments to the Federal Water Pollution
Control Act required the establishment of a National Pollutant Discharge
Elimination System (NPDES) permit program. Permits issued to industrial
and municipal sources by EPA or by the State, under EPA auspices, require
the permittee to monitor effluents to verify compliance with limitations
on specified parameters. Periodically, data are submitted to the permit-
ting agency in a discharge monitoring report (DMR). Based on these
reports, assuming the data submitted are valid, a regulatory authority
can determine if the permittee is in compliance.
The EPA has used a variety of methods to determine facility com-
pliance with NPDES permit requirements. These methods range from a
Compliance Evaluation Inspection (CEI) lasting several hours, to a
Compliance Sampling Inspection (CSI) extending over several days to
weeks, with 24-hour composite sampling of numerous Outfalls. The CEI
allows compliance to be determined primarily through observation,
records review, and discussion with the permittee; for example, "Are
compliance schedules being met?" "Is self-monitoring being conducted?"
The CSI addresses these aspects and in addition, allows a direct deter-
mination of compliance with the permit limitations. It can also in-
clude an evaluation of actual techniques employed by the permittee in
performing the self-monitoring requirements of sampling, flow-monitoring,
analyses, quality control, record keeping, and reporting. This latter
evaluation is important because it provides an effective means to
determine the validity of the DMR data. This in turn is important
because considerable emphasis is placed on tracking DMR data for permit
compliance.
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Because a CSI is resource intensive and does not usually include
an evaluation of the permittee's self-monitoring practices, the concept
of performance audit inspections (PAI) for municipal and industrial
wastewater sources was developed. The primary objectives of the PAI
are to evaluate the permittee's sampling techniques, analytical proced-
ures, quality control procedures, DMR data, and compliance schedules.
The NEIC has conducted over one hundred thirty PAI's during the
past three years. This inspection procedure has been found to be:
1. An effective technique for evaluating the acceptability of
DMR data and identifying and achieving correction of self-
monitoring deficiencies.
2. A valuable screening technique through which serious pollu-
tion problems can be identified for followup action.
3. Less resource intensive than a compliance sampling inspec-
tion; the average work days* spent on a PAI is 12 or
slightly less than 40 percent of the 32 workdays* NEIC
spent on a compliance monitoring inspection or CSI.
The procedures NEIC personnel used in conducting a PAI are discussed
in the following sections. Throughout these inspections the investiga-
tors followed the applicable NEIC Chain-of-Custody and document control
procedures.
* Direct costs only.
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II. BACKGROUND REVIEW
Prior to conducting a performance audit inspection (PAI) the
available background information was reviewed. This review has been
found essential for effectively planning a PAI. It provides infor-
mation on the permittee's operations, permit limitations in force,
compliance schedules, self-monitoring requirements, and past history
of violations. Some sources of background information generally re-
viewed are listed below.
A. NPDES Permit Application - The application provides data on
wastewater characterization, water pollution control prac-
tices, water use, wastewater flows, numbers, and types of
discharges (e.g., process wastewater, and cooling waters).
B. NPDES Permit
1. Effluent limitations - This portion of the permit pro-
vides information on qualitative and quantitative limi-
tations; for example: average and maximum concentrations,
average daily and maximum daily loads.
2. Self-monitoring Requirements - This portion provides
the frequency and type of sampling (grab or composite)
and the flow-monitoring, analytical, and data reporting
requirements.
3. Compliance Schedule - This provides the schedule of
events the permittee must accomplish to abate pollution
and comply with the specified effluent limitations.
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£• DHR Data - Provides a record of effluent quality and permit-
tee compliance based on self-monitoring data. A review of
the data for the past year generally provides a good back-
ground.
D. Previous Inspection Reports - Inspection reports from EPA
Regional and State files, which may describe the process
operations and pollution control practices, provide the
investigator team details on pollution problems. In addi-
tion, a review of available site maps and process and waste-
water treatment flow diagrams are beneficial in providing
familiarity with permittee operations.
E. Regional andState Files
A review of both State and EPA regional files can pro-
vide the compliance history of the permittee. Consultant
reports prepared for the permittee on pollution abatement
facilities are generally good sources of information. Aerial
photography, if available, are helpful in gaining familiarity
with the source.
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III. NOTIFICATION AND ENTRY
Before conducting an inspection a 308 letter was generally sent
to the permittee defining the authority, the general outline the per-
formance audit would take, the information and data that was to be
furnished during the inspection, and the self-monitoring that would
be evaluated [Appendix A]. The letters either stated the exact dates
when the performance audit inspection was to be conducted, or it gave
a general time frame, such as 'within the next six months'. The speci-
ficity of the dates depends on the self-monitoring frequency and desired
results. If the permittee conducts daily monitoring, a general time
period is adequate; however, if the permittee monitors infrequently
(e.g., once-per-week), more specific dates are necessary. Using non-
specific dates essentially makes the inspection "unannounced" but it
also increases the risk of responsible officials being absent.
Authority to gain entry to the site is provided in the Clean
Water Act, Section 308 (a)(B) which states, "The Administrator or his
authorized representative upon presentation of his credentials—(i)
shall have the right of entry to, upon, or through any premises in
which an effluent source is located or in which any records required
to be maintained... are located, and (ii) may at reasonable times
have access to and copy any records, inspect any monitoring equipment
or method required..., and sample any effluents which the owner or
operator or such source is required to sample for... ." The NEIC
investigating team entered the plant through the main gate or through
an entrance designated by the permittee in response to the notifica-
tion (308) letter. Upon entering, the investigators introduced them-
selves to a responsible plant official who was either the owner, op-
erator, officer, or agent in charge of the facility. Identification
credentials were presented.
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Many companies required that the inspection team upon entering a
facility, sign a visitor's sheet. This sheet generally had blanks
for the name, times, reason for visit, organization, etc., and the
investigators would sign it. On some occasions the visitor sheet
contained a "Visitor's Release" (waiver) relieving the Company from
any liability. NEIC employees have been instructed not to sign a
sheet containing such a waiver statement. Once the investigators
explained to the responsible official that they were not permitted by
agency policy to sign such a waiver, the waiver statement was either
crossed out or the team was asked to sign a sheet containing no waiver
statement.
Entry to a facility was never refused even in those cases where
no specific inspection dates had been provided in the 308 letter.
Employees had been instructed that if entry was refused, they should
not contest the issue with representatives but should obtain the name
and position of the individual representing the permittee and the
reasons for refusing entry. The inspection team were then to leave
the premises immediately and telephone the Enforcement Specialist as
soon as possible for further instructions. Subsequent attempts to
secure entry would then be through appropriate legal procedures.
Employees were instructed to completely document the entire sequence
of events concerning any refusal of entry.
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IV. FACILITY INSPECTION
The investigating team assigned to conduct the performance audit
inspection was dictated by the complexity of the source and the moni-
toring requirements. Generally the team consisted of people with
knowledge and skills in: (a) flow-monitoring techniques, including
the installation and calibration of flow-measurement devices and in-
struments, (b) sampling techniques including automatic sampling de-
vices, preservation requirements, holding times, etc., (c) analytical
procedures for specified permit parameters, (d) bio-monitoring/micro-
biological procedures, if required by the permit, and, where necessary,
e) waste treatment technology, operation and maintenance practices,
and industrial production processes.
The on-site inspection was directed primarily toward verifying
the accuracy of existing (EPA, State) file information, observing and
evaluating sampling, flow-monitoring and analytical procedures and
techniques, reviewing the record-keeping procedures, determining if
NPDES compliance schedules were being met and, where appropriate,
evaluating operation and maintenance practices.
Discussed below are the areas the NEIC inspection teams ad-
dressed during the PAI's:
A, Determine if file information on process operations and
plant production rates, where applicable, is current; de-
termine if existing information on wastewater treatment
practices is correct. In many instances background infor-
mation on these areas did not exist or was limited and
had to be developed during the inspection.
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B. Determine if the number and location of the discharges are
as described in the permit, and if there are any unpermitted
discharges. Photographs are very useful in documenting the
latter-type information.
C. Determine if the compliance schedules in the permit are
being, or have been met.
D. Determine if all pertinent parameters are being monitored;
for example, have changes in the manufacturing processes or
waste treatment practices occurred and resulted in different
discharge characteristics which may require changes in moni-
toring.
E. Evaluate permittee sampling procedures in terms of represen-
tativeness, frequency, type of sample (grab or composite),
compositing techniques (flow proportional or not), type of
containers used for specific parameters, and methods of
collection (automatic or manual techniques).
F. Evaluate flow-monitoring equipment and procedures in terms
of:
a) Acceptability of devices used, that is proper instal-
lation, location, and accuracy of measurement.
b) Frequency of flow-measurement, for example: continuous or
instantaneous.
c) Calibration and quality control procedures used to verify
accuracy in measurement devices and instruments.
d) Maintenance procedures followed for measurement devices
and instruments.
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G. Evaluate analytical procedures in terms of:
a) Preservation techniques and holding times for samples.
b) Methods used for parameters specified in the permit
compared to 304 (h) requirements,
c) Methods and adequacy of instrument calibration and
state of instrument repair.
d) Adequacy of the quality control/quality assurance
(QC/QA) program for all analyses including those
performed by automated equipment.
e) Record-keeping of bench data and accuracy of
calculations.
f) Necessary approvals for use of modified procedures.
The NEIC generally requested the permittee or the con-
tract laboratory providing analytical services to analyze
performance/verification samples. This was an useful means
of determining if the permittee's laboratory data were re-
liable. The investigators requested that the results be
sent to EPA as soon as the analyses were completed. However,
there were some long delays in receiving the results. This
step in evaluating the permittee's analytical performance
could have been expedited by sending the samples in advance
of the inspection.
H. Review records the permittee uses to prepare the DMRs, such
as laboratory bench sheets and flow-monitoring records.
These data were selected at random and tracked from genera-
tion in the laboratory to the DMRs.
Although the performance audit was designed to provide informa-
tion concerning the validity of DMR data by evaluating self-monitoring
procedures, it was also used to collect other important information.
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For example, evaluations of wastewater treatment plant operation and
maintenance (O&M) practices were made during some facility inspec-
tions. From this evaluation, the effects of O&M practices on the
self-monitoring data could be examined. In addition, an evaluation
of the treatment facility design vs. actual conditions was made to
determine if the system was over, or under, design load either organi-
cally or hydraulically.
Following the inspection of the plant, the investigators met
with the permittee for an informal discussion of their findings. The
issues addressed were deviations from prescribed and/or recommended
procedures. The team advised the permittee of the proper procedures
and techniques to be followed. It was generally noted that once the
permittee understood the objectives of the performance audit inspec-
tion — to improve the accuracy of their self-monitoring procedures
and the results — the majority welcomed the information and advice
provided them.
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V. FOLLOWUP ACTION
Subsequent to the performance audit inspection, a written report*
such as that contained in Appendix B was prepared. The report dis-
cussed discrepancies or deviations from prescribed or recommended
policies. These reports were sent to the requesting Regional office
for appropriate action where the discrepancies were deviations from
required self-monitoring procedures and techniques; some Regional
offices issued Administrative orders to achieve correction. A follow-
up inspection to determine the corrective action taken was conducted
by Regional and/or NEIC personnel. Generally, NEIC investigators
found during the followup inspections that the permittees were making
a conscious effort to correct the deficiencies in self-monitoring
practices. Although, the NEIC did not experience the situation, judi-
cial referrals for demonstrated bad faith by failure to correct the
deficiencies as ordered, could be taken. Moreover, if the performance
audit would have revealed that, for example, compliance schedules were
not being met, there were unpermitted discharges, or there was falsifi-
cation of the records, a judicial referral could be made initially.
The performance audit inspection followed by a followup inspec-
tion provided a means of assessing the DMR data and improving that
data. The PAI was found less resource-demanding than a compliance
sampling inspection (CSI) and worked effectively as a screening device
to locate major pollution problems, which could then be scheduled for
an intensive CSI if necessary.
In conducting an inspection, the NEIC used a variety of checklists
to aid in collecting information. These checklists were found to
be helpful in streamlining the inspection, but it was emphasized
to the investigation team that the checklists were to be used as
tools, and not the driving force. That is, the inspection should
be more than just the completion of blank forms.
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APPENDIX A
SAMPLE 308 LETTERS
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A-l
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 inspec-
tion of your Company's manufacturing operations, together with asso-
ciated 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 conducting the inspections
will be authorized representatives of the Environmental Protection
Administration as referred to in Section 308 and will present appro-
priate credentials. They will observe your process operations;
inspect and evaluate your monitoring/field/laboratory equipment and
methods; examine monitoring and calibration records and other appro-
priate 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 manufacturing
location.
It is requested that plant process flow diagrams, waste treatment
plant How diagrams, and treatment plant design data be made available
to the inspectors during the first day of their inspection.
The EPA inspectors will also provide verification samples for
analytical evalution 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.
Please inform the appropriate plant personnel to expect such an
inspection to ensure a rapid plant entry and to ensure that these
surveys are conducted without unnecessary delay.
We will appreciate your full cooperation in this matter.
Sincerely yours,
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A-2
Date
Dear Mr. :
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, specifically, the NEIC office in
Denver, Colorado and/or Region will conduct an inspection of your
Company's manufacturing operations together with associated waste
treatment and discharge facilities. The inspection is planned for
the week of and is intended to determine degree of
compliance with the requirements of the National Pollutant Discharge
Elimination System issued to your Company.
Our representatives will observe your process operations, inspect and
evaluate your monitoring/field/laboratory equipment and methods;
examine appropriate records; and will be concerned with related
matters.
The EPA visit will focus on procedures, and accordingly, it is reques-
ted that Company monitoring under conditions of the NPDES permit be
scheduled to precisely correspond with this inspection. We ask only
that the Company conduct its monitoring (for all parameters, if at
all possible) under normal procedures and practices. On-the-spot
observation shall be made of sample collection, any field preserva-
tion of samples, handling and transport of samples, field and analy-
tical equipment in operation, and the actual conduct of analytical/
laboratory procedures. If analyses are conducted by an ouside contrac-
tor, please notify your agent that EPA personnel will evaluate analy-
tical tests and methods as they are being performed. Please inform
us if these tests are conducted elsewhere than at your main manufac-
turing location.
Please provide the name of any "new" individual whom we may not have
had contact with in the past (if such is necessary) to enable our
access to the plant. We would appreciate a list of safety equipment
if required by our people. Any reports or information that may be
considered confidential by you will be treated in accordance with
Section 308(b) of the Act, but should be properly identified as such
to the EPA, and necessary reasons for confidential claims may need to
be made available to the EPA. However, "effluent data" is always
considered accessible to the public.
If you have any questions concerning this inspection, please telephone
, NEIC, Denver at .
Sincerely yours,
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APPENDIX B
TYPICAL PILOT COMPLIANCE MONITORING INSPECTION REPORT
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Environmental Protection Agency B_-|
Office of Enforcement
COMPLIANCE MONITORING EVALUATION
October 27, 1977
National Enforcement Investigations Center
Denver, Colorado
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B-2
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B-3
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 MPDES 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.
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 ano requested that the
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B-4
sample be analyzed and the data results returned to the NEIC within two
weeks. The Company uses the contract laboratory services of Labora-
tories in for analysis of their 5-day Biochemical
Oxygen Demand (BOD5) 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 BODr sample and requested that
both the spiked and unspiked samples be analyzed by . NEIC personnel
also visited Laboratories on November 9th and evaluated their
labo. atory technique" In addition, NEIC personnel split with the
Company personnel the daily wastewater composite sample obtained by the
Cc..^any 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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B-5
SUMMARY AND CONCLUSIONS
On October 27, 1977 personnel from the National Enforcement Invest!
gations Center (NEIC) conducted an NPDES pilot compliance monitoring
inspection at the Wastewater
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 sensor 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
were determined. These values were compared against the flow recorder
values for the same times. The Company data was approximately IIS 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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B-6
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 sfarp-crested
rectangular weir and may not be obtaining a true flow proportioned
sample wit'i 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 BOD,- 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
BODj. analyses. The daily composite BOD^ samples are acidified and
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B-7
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 BODr data
0
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 performing the TSS analyses.
Analytical procedures used by Laboratories for the
w
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 hot 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
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B-8
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 38% to 88% and 11 to 65%,
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 ft .is therefore not possible to determine the Company's
degree of compliance with the flPDES permit requirements.
The Company does appear to have met all of the compliance dates
stipulated in the permit.
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B-9
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 4°C during the compositing
period.
4. The BOD5 sample holding/preservation procedures should be
revised to ensure that the samples are held at 4°C 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 BOD5 sample holding/preservation pro-
cedures yield accurate data.
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B-10
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 BODr 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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B-n
COMPLIANCE MONITORING EVALUATION REPORT
Date: 10/27/77
ignT)
Time 7 :1 z^f
Region
,-ACILlTY
NAME
COU.JTY
Responsible Official
NPDES Permit No.
LOCATION
MUNICIPALITY
Title
Permit Expiration Date
STATE
Telephone Ho.
Receiving Stream
Inspection Attendees
Affiliation
William Abbott
David Brooman
USEPA-flEIC
USEPA-NEIC
Type of Facility and General Process Description
The Company manufactures about tons/day of paper napkins from
reclainied 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 EVALUATION
( 1)
(2 )
(4 )
1.
2.
3.
Records and Reports
Operations and
Maintenance
Sarcoling Procedures
(4)
(2)
if!
4.
5.
6.
7.
1 = Satisfactory
2 = Unsatisfactory
Flow lleasurenents
Laboratory Procedures
Sludge Disposal Practices
Alternate Power
(1)8.
<3>9-
3 = N.A.
4 = Undeterrr.ined
Unathorized Discharge
Other
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33
I
IN3
WOES Permi
Outfall
No.
001
t Monitoring Requi
rements
Source of Parameter
Wastewater
Effluent from
wastewater
treatment
facility
serving
paper makipg
operations*
BOD,-
b
TSS
PH
Flow
(Effective
Quantity
Avq. Day
kg/day (Ih/day)
250(550)
300(660)
)
Limitations
Quantity Concentration
Max. Day Avg. Day
kn/day (Ib/day) mq/i
500(1100)
600(1320)
(6.0 to 9.0 units
range)
Monitoring
Frequency
Daily
Daily
Daily
__*
Sample
Tyne
24 hr. Compos it
24 hr. Compos il
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.
-------
B-13
Description of llastewater 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 60-702 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 puinped 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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B-14
Effluent from the 40 ft. clarifier is routed to the first stage of
a two-stage activated sludge system. The wastewater 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 whicn traverses the length of the 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 GOD,- 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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B-15
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, uastewaters resulting from basement flooding would be
-------
B-16
diverted by gravity to the emergency spill basin. The contents of the
70 ft. clanfier 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.
-------
B-17
A v-w_i j 11" . ,
Activate ch
-------
B-18
Average Treated Has tewater Flow of Faci1ity? Approximately 1.0 MOD
Averaoe Design F1ow of Mastewater Treatment Facility: 1.0 MGD
Alternate Electric Power Source fXX"' Dual Feed / / Renerator / / None
~~7 Other (Explain):
Adequats Alarm System for Power or Equipment Failures? J? Yes /~7 No
If no, explain:
Observed Appearance of Effluent, Receiving Stream or Drainage '-/ay:
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
ana Maintenance Problems? /v~~' Yes /~~~ No
LJ^j L-J
If yes, who?
Are lagoons Used in Treatment Process? ,/x- Yes /==t No
If yes, what is treatment function? jhe 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? QJ Yes /~7 No If yes, what material?
The lagoon will be clay lined
Condition of lining?
The lagoon was still under construction
Condition of dikes?
Still under construction.
Any seepaoe evident? (__/ Yes • x/ No
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B-19
NOTATIONS 8Y EVALUATOH
OPEq*-|C'l .'.O VAlriTE.-: asCE PPCOLC"! EE *ICI ENCI ES
C'-'CC" E * C •* 3*" "-E •••OLL ?«INC I'E^S I'. TE"*.'S OF Tr-ClP FSTlMftTFD ASPERSE * e *" E C T OS T n E PERFORMANCE O e- • ^ e- pt_..- -
IT EM
S~ •' • f C2^ = t. :"E"T
"EIIO.1.1- =!. TT»IM'IG
c?i"J"" o : UOC:T
L^'J'ATC3 ' ;3'.T=OL
I'.STTJ"C IT-TIC'i
l'.2'wfT=l-'. «SST£ [ij /\
P-ANT CuSCL£5£MCE
EC'JIS";'.T c»!LUr1E
THE»Tli/C«JT PnOCECSES
SLUOIE HANDLING
AN? PROCESSING
ECUIPMEH- MilNTENiNCE
SP*Pi '-'iRTS 1 IVE'iTOa Y
PO*En FAILLf=;i
M.JOS
X
X
X
v
h>iNOR
NONE
X
y
X
X
\
X
x
X
ITEM
O.-ERLOiOS 't.pc;
MVDR »ULIC
PCRIOCIC
CONTINUOUS
ORC ANIC
PERIODIC
COrtTINUOUS
OVE°LO^O C AUSEIS)
Unit underdesigned
ind/or mill water recycle
nroaram has not been
maximized
OTHER
Treatment Plant Design
MA J30
X
X
X
X
X
MIISC^ '.O'.£
X
X
Y
V
1
1
DESCRIBE BRIEFLY TrlE MAJOR PROBLEMS IN3ICATCD 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: Problems were noted with the weir installation at
Outfall 001 as discussed 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 flow 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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B-20
SELF-MONITORING
On the foil ovn' nq items, code 1 = yes, 2 = no, 3 = undetermined,
4 = not applicable.
RECORDS AND REPORTS
T~ 1. Prooerly maintained records of date, exact place and time of
sampling.
£\7 2. Properly maintained records of the dates samples were analyzed.
/T" 3. Prooerly maintained records of who performed the analyses.
_ 4. Properly maintained records of the analytical techniques and
methods used.
17 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).
f~-\~/ 7. Plant operating records kept including operating logs of each
treatment unit.
/j7 8. Results of sample analyses correctly calculated and recorded.
f~\/ 9. Self-monitoring frequency and oarameters conform to permit
requirements.
,'J7 10- Laboratory records consistent with DMR data.
/"a/ 11- Records maintained of major contributina industries using
publicly owned treatment works.
' 12. Records maintained of major contributing industries' compliance/
non-compliance status.
/j7 13. Quality assurance records kept including spiked samples, laboratory
equipment calibration, etc.
Other Comments on Records and Reports:
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B-21
FLO'-.' MEASUREMENT NOTE: l=Yes, 2=ilo, 3=Undetermined. 4=Not applicable
/j3 1. Primary measuring device (weir, parshall flume, magmeter, etc.)
properly installed.
Type of device See note below .
~Y 2. Calibration frequency adequate.
Date of last calibration Monthly
_'~] 3, Flow measurement records properly maintained.
Method (automatic, manual, etc.) Automatic
/~3 4. Primary flow measurement device properly operated and maintained.
/~J 5. Secondary instruments (totalizers, records, etc.) properly
operated and maintained.
/""I 5. Flow measurement equipment adequate to handle expected ranqes of
flow rates.
OtherComments 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 instaMation
are that the weir is not sharp 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- 2". 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 111 low at about 1200gpm and
36% low at about BOOgpm. 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
/1~7 1. Locations adequate for representative samples.
Xj7 2. Parameters and frequency agree with permit.
/y 3. Method of sample collection: Hanual '"j
Automatic jf7
/'~ 4. Sample collection method is adequate. See note 1 on next page.
/jj~ 5. Water intake sampled and analyzed, if required by permit.
/""]" 6. Additional monitorinq and analyses beinq performed more
frequently than required by permit.
-------
1 = Yes, 2 = No, 3 = Undetermined, 4 = Hot applicable
B-22 __
2 7. '-/hen answer to No. 6 is yes, results are beinn reoorted in
permittee's Discharge Monitorina Form (EPA Mo. 3320-1).
/~ 8. When necessary during compositinci, samples are prooerly iced.
, ~ 9. Proper preservation techniques used. See Mote 2 be.1ow
_j~ 10. Flow proportioned samples obtained where required by nermit.
See Note 1 below.
• 2 11- Sample holdina times prior to analyses in conformance with 40
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
SN34450, 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 -!s stored at the
ambient temoerature of the sampling shed. 3)The BOD.- samples which are sent
tc a contract lauoratory for analysis are not analyzid within the 6-hour
holding time recommended by the EPA.
LABORATORY PROCEDURES:
/2/ 1. . EPA approved analytical testing orocedures used (40 CFR 136.3).
/_2_-' 2. If alternate analytical procedures are used, proper approval
has been obtained.
fij 3. Parameters other than those required by the permit are analyzed.
/~\7 4. Commercial laboratory utilized.
(For BODj. analysis only) Name
3 Address_
/~ 5. Commercial laboratory State certified.
/j7 6. Satisfactory calibration and maintenance of instruments and
equipment.
/P 7. Quality control procedures used. see note 1 on next paae
/?/ 8. Duplicate samples are analyzed. % of time.
See Note 1.
-------
1 = Yes, 2 = No, 3 = Undetermined, 4 = Not applicable B~23
9- Spiked samples are used. % of time.
/j~ 10. Laboratory records properly maintained.
/j~" 11. Laboratory employees qualified.
General Comments on LaboratoryProcedures:
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 BOD^ 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.
Resultsjjf NEIC Quality Control Check SamplesAnalyzed byLaboratory
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 Cgmpany-EPA NEIC 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.
-------
B-24 1 = Yes, 2 = flo, 3 = Undetermined, 4 = Mot applicable
OPERATION AND MAINTENANCE
1. Standby pov/er or other equivalent provisions provided.
~ 2. Adequate alarm system for pov;er or equipment failures available.
~' 3. Reoorts on alternate source of power sent to EPA/State as
required by permit.
'"T 4. Sludges and solids adequately disposed. Sludge disposal site
was not observed.
2 5. Any non-permitted discharges.
6. Any by-passing since last inspection.
7. Regulatory agency notified of by-passing.
Dates ,
,_2 8. Any effluent limitations violations experienced.
,~ 9. All treatment units in service.
/iTT 10. Any hydraulic and/or organic overloads experienced.
_2, 11. Treatment facility properly operated and maintained. See notes belo1..
12. Consulting engineer retained or available for consultation on
. operation and maintenance problems.
13. Preventive maintenance records files kept.
14. Qualified operating staff provided.
15. Established procedures available for training new operators.
16. Files maintained on spare parts inventory, major equipment
specifications, and parts and equipment suppliers.
. 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
-------
1 = Yes, 2 = Mo, 3 = Undetermined, 4 = Not applicable B"25
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
/1 1. Correct name and mailing address of permittee.
£a/ 2. Facility as described in permit.
/j7 3. Principal product or products, and production rates conform
with those set forth in permit application.
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.
1 } 7• Number and location of discharge points as described in permit,
/T1 8. Correct name and location of receiving waters.
------- |