United States
Environmental Protection
Agency
Enforcement And
Compliance Assurance
(2223A)
EPA300-B-95-016
September 1995
NPDES Compliance Inspection
Training Program Student's
Guide
Printed on Recycled Paper
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NPDES COMPLIANCE INSPECTION
TRAINING PROGRAM
STUDENT'S GUIDE
FINAL
September 1995
Submitted to:
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
12th and Pennsylvania Avenues, NW
Washington, DC 20044
Submitted by:
Science Applications International Corporation
1710 Goodridge Drive
McLean, VA 22102
EPA Contract No. 68-C4-0072, WA No. EC-0-2 (OC)
SAIC Project No. 01-1030-07-2201-100
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DISCLAIMER
DISCLAIMER
This Student's Guide represents the introductory training on selected topics related to the conduct of NPDES
compliance inspections developed by the U.S. Environmental Protection Agency Office of Enforcement and Compliance
Assurance. Failure on the part of any duly authorized official, inspector, or agent to comply with its contents shall not
be a defense in any enforcement action, nor shall a failure to comply with this guidance alone constitute grounds for
rendering evidence obtained thereby inadmissible in a court of law. The mention of trade names or commercial products
constitutes neither endorsement nor recommendation for use.
NPDES INSPECTION MANUAL SEPTEMBER 1995
STUDENT'S GUIDE
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TABLE OF CONTENTS
TABLE OF CONTENTS
Page
FOREWORD iv
SCHEDULE/CHECKLIST vi
UNIT ONE - INTRODUCTION 1-1
EXERCISE 1-1 LEGAL AUTHORITY FOR NPDES INSPECTIONS 1-1
EXERCISE 1-2 NPDES PERMITTING REGULATIONS 1-4
EXERCISE 1-3 RESPONSIBILITIES OF THE NPDES INSPECTOR 1-6
UNIT 1 EXAM 1-8
UNIT TWO - INSPECTION PROCEDURES 2-1
EXERCISE 2-1 PLANNING AND PREPARING FOR AN INSPECTION 2-1
EXERCISE 2-2 ENTERING THE FACILITY 2-5
EXERCISE 2-3 CONDUCTING THE OPENING CONFERENCE 2-7
EXERCISE 2-4 DOCUMENTATION 2-8
EXERCISE 2-5 CONDUCTING THE CLOSING CONFERENCE 2-11
EXERCISE 2-6 PREPARING THE INSPECTION REPORT 2-12
UNIT 2 EXAM 2-13
UNIT THREE - DOCUMENTATION/RECORD KEEPING AND REPORTING 3-1
EXERCISE 3-1 INSPECTION AUTHORITY AND EVALUATION PROCEDURES FOR
FACILITY RECORD REVIEWS 3-1
EXERCISE 3-2 SUMMARY/REVIEW (OPTIONAL) 3-4
UNIT 3 EXAM 3-5
UNIT FOUR - FACILITY SITE REVIEW 4-1
EXERCISE 4-1 PHYSICAL INSPECTION OF THE FACILITY 4-1
EXERCISE 4-2 O&M EVALUATION 4-4
EXERCISE 4-3 SUMMARY OF TREATMENT UNITS AND OPERATIONS THAT SHOULD BE
INSPECTED (OPTIONAL) 4-6
UNIT 4 EXAM 4-7
UNIT FIVE - SAMPLING 5-1
EXERCISE 5-1 EVALUATION OF PERMITTEE SAMPLING PROGRAM AND COMPLIANCE SAMPLING
5-1
EXERCISE 5-2 SAMPLING PROCEDURES AND TECHNIQUES 5-2
UNIT 5 EXAM 5-6
UNIT SIX - FLOW MEASUREMENT 6-1
EXERCISE 6-1 EVALUATION OF A PERMITTEE'S FLOW-MEASUREMENT EQUIPMENT AND
PROCEDURES 6-1
EXERCISE 6-2 FLOW-MEASUREMENT METHODS 6-3
EXERCISE 6-3 FLOW-MEASUREMENT COMPLIANCE INSPECTION PROCEDURES 6-6
UNIT 6 EXAM 6-9
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TABLE OF CONTENTS
TABLE OF CONTENTS (Continued)
Page
UNIT SEVEN - LABORATORY PROCEDURES QUALITY ASSURANCE 7-1
EXERCISE 7-1 OBJECTIVES AND REQUIREMENTS 7-1
EXERCISE 7-2 SAMPLE HANDLING PROCEDURES 7-3
EXERCISE 7-3 LABORATORY ANALYSES TECHNIQUES EVALUATION 7-3
EXERCISE 7-4 QA AND QC 7-6
UNIT 7 EXAM 7-9
UNIT EIGHT - TOXICITY 8-1
EXERCISE 8-1 OBJECTIVES 8-2
EXERCISE 8-2 REQUIREMENTS OF WET TESTING 8-3
EXERCISE 8-3 ANALYSIS OF RESULTS 8-6
UNIT 8 EXAM 8-7
UNIT NINE - PRETREATMENT 9-1
EXERCISE 9-1 REVIEW OF THE GENERAL PRETREATMENT REGULATIONS 9-1
EXERCISE 9-2 PCIs AND AUDITS 9-4
UNIT 9 EXAM 9-5
UNIT TEN - SEWAGE SLUDGE 10-1
EXERCISE 10-1 REVIEW OF THE SEWAGE SLUDGE REGULATIONS 10-1
EXERCISE 10-2 SLUDGE INSPECTION PROCEDURES 10-3
UNIT 10 EXAM 10-6
UNIT ELEVEN - STORM WATER 11-1
EXERCISE 11-1 STORM WATER REGULATIONS 11-1
EXERCISE 11-2 STORM WATER PERMITS 11-3
EXERCISE 11-3 SAMPLING AND INSPECTION CONSIDERATIONS 11-5
UNIT 11 EXAM 11-7
UNIT TWELVE - COMBINED SEWER OVERFLOWS 12-1
EXERCISE 12-1 THE CSO CONTROL POLICY 12-1
EXERCISE 12-2 CSO INSPECTION PROCEDURES 12-3
UNIT 12 EXAM 12-5
UNIT THIRTEEN - POLLUTION PREVENTION 13-1
EXERCISE 13-1 OVERVIEW OF POLLUTION PREVENTION 13-1
EXERCISE 13-2 POLLUTION PREVENTION FOR INDUSTRIAL FACILITIES 13-3
EXERCISE 13-3 POLLUTION PREVENTION FOR MUNICIPAL WASTEWATER TREATMENT
PLANTS 13-5
UNIT 13 EXAM 13-6
UNIT FOURTEEN - MULTI-MEDIA CONCERNS 14-1
EXERCISE 14-1 INTRODUCTION AND OVERVIEW 14-1
EXERCISE 14-2 MULTI-MEDIA CONCERNS AND THE SCREENING PROCESS 14-3
EXERCISE 14-3 MULTI-MEDIA INSPECTIONS 14-4
UNIT 14 EXAM 14-5
FINAL EXAM Appendix A
REFERENCES Appendix B
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FOREWORD
FOREWORD
To prepare novice inspectors to conduct complete and accurate inspections under the National Pollutant Discharge
Elimination System (NPDES) program, the Office of Enforcement and Compliance Assurance of the U.S. Environmental
Protection Agency (EPA) has developed the NPDES Compliance Inspection Training Program, which is designed for
independent study. The student works under the guidance of an experienced inspector or "instructor" to complete the
NPDES Compliance Inspection Training Program Student's Guide (hereafter referred to as the "Guide" and to perform
a period of intensive field work. The program reviews the Clean Water Act (CWA) and focuses on the basic policies,
procedures, and techniques involved in NPDES inspections. The program's primary references are EPA's 1994 NPDES
Compliance Inspection Manual (hereafter referred to as the "Manual") and the following EPA 1990 NPDES Compliance
Monitoring Inspector Training Modules.
• Overview - Presents a review of the NPDES program and briefly summarizes the different types of inspections
• Legal Issues - Discusses the legal issues which must be addressed during an inspection and provides legal
information to assist inspectors
• Biomonitoring - Outlines the principles of biomonitoring and the role of biological testing in the NPDES
inspection program
• Sampling Procedures - Details procedures to be used when conducting sampling
• Laboratory Analysis - Outlines procedures and information necessary to perform an effective evaluation of a
permittee's laboratory.
The period of intensive field work accomplished under the guidance of the instructor is intended to provide the
student with practical "hands-on" experience and to reinforce the information presented in the Guide. The student's
performance is evaluated regularly by the instructor, who makes recommendations for additional work (if necessary).
This document is the Student's Guide in the NPDES Compliance Inspection Training Program; it provides directed
study and questions on the Manual, the five training modules, the CWA, and relevant regulations. This guide contains
14 self-study units that lead the student through the reference materials, test his/her understanding of the topics discussed,
and prepare him/her for independent field inspections.
HOW THE PROGRAM WORKS
Each unit consists of a series of activities that explore, review, and reinforce:
• Standard inspection procedures
• Techniques for defensible evidence collection
• The overall NPDES enforcement program.
Each unit contains at least one exercise that includes a reading assignment and a study checklist. The study
checklist includes questions that the student should be able to answer after completing the reading assignment. The
student should first read through the study checklist and respond to as many items as possible. This will help focus the
material presented in the reading assignment and identify areas that will need detailed study. The student should then
complete the recommended reading assignment. After reading all the assigned materials, the student should return to
the study checklist and respond to each question. The student should work through the checklist, correcting any errors
SEPTEMBER 1995 NPDES INSPECTION MANUAL
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FOREWORD
made the first time. If questions persist, they should be discussed with the instructor. The student must not proceed to
the next exercise until each item on the checklist is completed correctly. The study checklists within each unit include
the appropriate references where the answers to the questions can be found. Each unit also contains an exam which is
to be completed after the student has finished each exercise in that unit. This exam does not contain references. A final
exam will be given to the student after completion of all the units.
Most units contain several exercises which require the student to use basic unit information to solve problems that
inspectors often face in the field. Responses to many of these exercises are not simply right or wrong, but are open to
interpretation and discussion. It is important that the student and instructor review and discuss the student's responses.
NPDES INSPECTION MANUAL SEPTEMBER 1995
STUDENT'S GUIDE iv
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SCHEDULE/CHECKLIST
STUDY UNIT
1 . Introduction
2. Inspection Procedures
3. Documentation/Record
Keeping and Reporting
4. Facility Site Review
5 . Sampling
6. Flow Measurement
7. Laboratory Procedures
and Quality Assurance
8. Toxicity
9. Pretreatment
10. Sewage Sludge
1 1 . Storm Water
1 2 . Combined Sewer
Overflows
13. Pollution Prevention
14. Multi- Media Concerns
Final Exam
TOTAL
ESTIMATED TIME
TO COMPLETE
9 hours
6 hours 15 minutes
1 hour 30 minutes
5 hours
5 hours 45 minutes
3 hours 30 minutes
3 hours 15 minutes
5 hours 30 minutes
3 hours 15 minutes
2 hours 45 minutes
3 hours 15 minutes
1 hour 30 minutes
2 hours
2 hours 30 minutes
2 hour 30 minutes
57 hours 30 minutes
STUDENT
INSTRUCTOR
SCHEDULED
COMPLETION DATE
SATISFACTORY
COMPLETION
SEPTEMBER 1995
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INTRODUCTION UNIT 1
UNIT ONE
INTRODUCTION
The primary responsibility of an inspector is to inspect facilities for compliance with permit requirements. To
carry out this responsibility, inspectors must be knowledgeable of the CWA, the many procedural requirements and
responsibilities, and multimedia concerns involved in conducting a successful inspection. Unit One is designed to
familiarize the student with these program aspects.
Unit One corresponds to Chapter 1 of the Manual, select sections of the CWA, as amended, the NPDES
regulations, and EPA's 1990 NPDES Compliance Monitoring Inspector Training Overview module. The exercises
included in this unit cover:
• Legal authority for NPDES inspections
• NPDES permitting regulations
• Responsibilities of the NPDES inspector.
EXERCISE 1-1 LEGAL AUTHORITY FOR 3 HOURS
NPDES INSPECTIONS 30 MINUTES
To carry out their duties effectively, inspectors must be thoroughly familiar with the legal bases for their actions.
A clear understanding of the objective, purpose, scope, and requirements of the CWA is imperative.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapters 1A and IB of the Manual and Chapters 1 and 2 of the NPDES Compliance Monitoring Inspector
Training Overview module.
3. Obtain a copy of the current CWA from your instructor. Read Sections 301, 303, 304, 308, 309, 402, 504, and
507.
4. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. State (in your own words) the objective of the CWA. (Overview module, Chapter 1, page 1-1)
2. Section 301(b)(l)(B) of the CWA requires Publicly Owned Treatment Works (POTWs) in existence on July 1, 1977,
or approved pursuant to Section 203 of the CWA prior to June 30, 1974, to meet effluent limits based on
3. List 5 things that must be taken into consideration when establishing new or revised water-quality standards [under
Section 303(c)(2)(A) of the CWA].
a.
b.
c.
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UNIT 1 INTRODUCTION
d.
e.
4. Section 304 of the CWA establishes a time table for EPA and States to develop and publish information on water
quality.
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
5. Indicate which part of Section 308 of the CWA addresses confidential information.
6. List two types of penalties available to EPA under Section 309 of the CWA.
a.
b.
7. Under Section 402 of the CWA, a permit may never be renewed, reissued, or modified to contain effluent
limitations which are less stringent then the effluent limits in the previous permit.
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
8. Describe the circumstances under which EPA may take action to immediately stop someone from discharging
pollutants. (CWA, Section 504)
9. Section 507 of the CWA sets forth protection for employees who testify or institute proceedings under the CWA.
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
10. Summarize the process by which EPA, under the CWA, regulates the discharge of pollutants into the Nation's
waterways. (Manual, Chapter IB, page 1-7)
11. List nine types of NPDES compliance inspections presented in the Manual Overview module. (Manual Chapter
1A, pages 1-1 through 1-3; Overview module, Chapter 2, pages 2-1 through 2-4)
a.
b.
c.
d.
e.
f.
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INTRODUCTION UNIT 1
EXERCISE 1-2 NPDES PERMITTING REGULATIONS 3 HOURS
The NPDES permitting regulations detail the regulatory requirements under which a permittee must operate a
facility to remain in compliance. This exercise will review those requirements that affect the inspector's
understanding of his/her responsibilities and ability to perform successful inspections.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Obtain a copy of the regulations [Code of Federal Regulations Title 10, Part 122 "EPA Administered Permit
Programs: The National Pollutant Discharge Elimination System."] from your instructor and read them.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. State (in your own words) the purpose and scope of the NPDES permitting regulations. [40 CFR 122.1]
2. List six things that must be included in a facility's monitoring records for each sample or measurement taken. [40
CFR 122.41 (j) (3)]
c.
d.
e.
f.
3. List two conditions under which a "bypass" will not result in an enforcement action.
[40 CFR 122.41(m)(2)&(4)[
4. List four conditions that a permittee must demonstrate to establish an "upset" as an affirmative defense.
[40 CFR 22.41 (n)(3)]
b.
c.
d.
5. Describe what production-based limits for existing facilities (except POTWs) should be based on.
[40 CFR 122.45(b)[
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UNIT 1 INTRODUCTION
6. Describe the manner in which permit effluent limitations for continuous-discharge POTWs should be stated. [40
CFR 122.45(d)]
7. List four factors that should be considered when limiting the discharges from noncontinuous-discharge facilities.
[40 CFR 122.45(e)]
a.
b.
c.
d.
8. Identify the maximum length of time for which a permit may be granted. [40 CFR 122.46]
9. Indicate by when compliance schedules must require compliance. [40 CFR 122.47(a)[
10. List three types of information specified in permits for the recording and reporting of monitoring results.
[40 CFR 122.48]
a.
b.
c.
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INTRODUCTION UNIT 1
EXERCISE 1-3 RESPONSIBILITIES OF THE NPDES INSPECTOR 2 HOURS
Inspections are the enforcement mechanisms for detecting and verifying violations of NPDES permits. Inspectors
must know and abide by the legal authority concerning inspections and the accepted procedures for conducting them.
This exercise focuses on the purpose, scope, and elements of various inspections, and the basic responsibilities of an
inspector.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 1C and Appendix A of the Manual and Chapters 3 through 5 of the NPDES Compliance Inspector
Training Overview module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made in
Step 1. Discuss any questions or problems with your instructor. Do not proceed until you mastered the material
in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. State the purposes of an inspection. (Manual, Chapter 1C, page 1-9)
2. List two legal requirements under which an inspector must conduct all NPDES inspections. (Manual, Chapter 1C,
page 1-9)
a.
b.
3. Summarize the inspector's responsibilities related to personal safety during an inspection. (Manual, Chapter 1C,
pages 1-10 through 1-11; Overview module, Chapter 4, page 4-3)
4. Summarize the responsibilities of an inspector relating to ethical conduct and professionalism during an inspection.
(Manual, Chapter 1C, pages 1-11 through 1-12; Overview module, Chapter 3, page 3-1)
5. Information from a permitted facility that has been classified as confidential may be withheld from an EPA or State
NPDES inspector. (Overview module, Chapter 3, page 3-2)
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
6. It is permissible for the NPDES inspector, after completing an inspection of a facility, to discuss both the findings
of the inspection and all violations identified with representatives of the permittee. (Overview module, Chapter
4, page 4-5)
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
7. Which of the following is not an objective of the Compliance Sampling Inspection (CSI)? (Circle correct answer.)
(Overview module, Chapter 5, pages 5-9 through 5-10)
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UNIT 1 INTRODUCTION
a. To verify compliance with permit effluent limits
b. To evaluate the permittee's laboratory techniques
c. To verify that parameters specified in the permit are consistent with the facility's wastewater characteristics
d. To gather information that may support enforcement actions.
8. Which of the following is not a component of a Compliance Evaluation Inspection (CEI)? (Circle correct answer.)
(Overview module, Chapter 5, page 5-1)
a. Facility site review
b. Compliance schedule review
c. Biomonitoring procedures review
d. Records and reports review.
9. A CSI is (more/less) resource-intensive than a CEI. (Circle correct answer.) (Overview module, Chapter 5, page
5-10)
10. It is the NPDES inspector's obligation during a Performance Audit Inspection (PAI) to be knowledgeable about
common permittee self-monitoring deficiencies. (Overview module, Chapter 5, page 5-12)
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
11. Which of the following is/are objectives of the records and reports review conducted as part of the CEI? (Circle
correct answer.) (Overview module, Chapter 5, page 5-2)
a. To identify trends in a permittee's effluent quality
b. To review the Quality Assurance (QA) system of a permittee's self-monitoring program
c. To document compliance/noncompliance with permit limitations and requirements
d. All of the above.
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INTRODUCTION UNIT 1
UNIT1
EXAM 30 MINUTES
Instructions
1.
2.
3.
4.
Complete this exam without referring to any text or notes.
Do not exceed the
Verify the answers
Correct any errors
time limit listed above.
with your instructor.
and clarify problems or questions before proceeding to Unit 2.
Exam Questions
1. Explain the process by which EPA, under the CWA, regulates the discharge of pollutants into the Nation's
waterways.
2. Explain the purpose of the NPDES permitting regulations.
3. According to 40 CFR 122.44 of the NPDES regulations, permits must include numerous conditions. List three
examples of these conditions.
a.
b.
c.
4. List two basic purposes of NPDES inspections.
a.
b.
5. Information from a permitted facility that has been classified as confidential may never be withheld from an
inspector.
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
6. Describe what a CSI focuses on.
7. A diagnostic inspection usually results in the issuance of a Administrative Order to conduct a detailed analysis to
correct the identified problem(s).
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
8. List the six activities commonly involved in NPDES inspections.
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UNIT 1 INTRODUCTION
a.
b.
c.
d.
e.
f.
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INSPECTION PROCEDURES UNIT 2
UNIT TWO
INSPECTION PROCEDURES
Section 308 of the CWA and NPDES regulations provide the general authority and limitations for inspections. The
terms and conditions of the NPDES permit, however, more precisely define the authority to inspect a permitted facility.
The scope of an NPDES inspection can be complex and will vary from facility to facility. However, inspection
procedures and guidelines have been established for those elements common to all inspections. Unit Two of this Guide
corresponds to Chapter 2 of the Manual, EPA's 1990 NPDES Compliance Monitoring Inspector Training Overview
module, and EPA's 1990 NPDES Compliance Monitoring Inspector Training Legal Issues module. Chapter 2 is divided
into the following six exercises:
• Planning and preparing for an inspection
• Entering the facility
• Conducting the opening conference
• Ensuring appropriate documentation
• Conducting the closing conference
• Preparing the inspection report.
EXERCISE 2-1 PLANNING AND PREPARING 2 HOURS
FOR AN INSPECTION
Proper planning and preparation are necessary to ensure that an inspection is conducted smoothly, efficiently, and
professionally. This exercise is designed to focus on the procedures involved in the preinspection process.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 2A and Appendix B of the Manual; review Chapter 4 and Appendices E through F of the NPDES
Compliance Monitoring Inspector Training Overview module; and read Chapters 1 through 5 and Appendix B
of the NPDES Compliance Monitoring Inspector Training Legal Issues module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Explain how facilities are selected for inspections. (Overview module, Appendix E; Legal Issues module, Chapter
4, pages 4-1 through 4-2).
2. List five sources of legal authority. (Legal Issues module, Chapter 1, page 1-3)
a.
b.
c.
d.
e.
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UNIT 2 INSPECTION PROCEDURES
3. EPA inspectors may visit a facility which has not been issued an NPDES permit. (Legal Issues module, Chapter
3, page 3-1)
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
4. List five sources of evidence regarding specific violations. (Legal Issues module, Chapter 4, page 4-2)
a.
b.
c.
d.
e.
5. Routine inspections should not be targeted at facilities in litigation with EPA. (Legal Issues module, Chapter 4,
pages 4-1 through 4-2)
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
6. Describe how facilities may be notified of an impending inspection. (Manual, Chapter 2A, page 2-6; Overview
module, Chapter 4, page 4-4; Legal Issues module, Chapter 4, page 4-2)
7. List three goals of reviewing facility background information prior to an inspection. (Manual, Chapter 2A, page
2-1)
a.
b.
c.
8. List three sources of facility background information. (Manual, Chapter 2A, pages 2-4 through 2-5)
a.
b.
c.
9. Explain how an inspector may determine what equipment and supplies might be needed during an inspection.
(Manual, Chapter 2A, pages 2-6 through 2-8; Overview module, Appendix F)
10. List six components or facets of an inspection that should be addressed during development of an inspection plan.
(Manual, Chapter 2A, pages 2-5 through 2-6)
a.
b.
c.
d.
e.
f.
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INSPECTION PROCEDURES UNIT 2
11. Claims of confidentiality must be asserted at the time of the inspection or they will be considered waived by the
permittee. (Legal Issues module, Chapter 4, page 4-3)
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
12. The procedures for handling claims of confidentiality are set out in . (Legal Issues module,
Chapter 4, page 4-4)
13. Inspectors should sign confidentiality or secrecy agreements if entry will be otherwise denied by the facility. (Legal
Issues module, Chapter 4, page 4-5)
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
14. Unauthorized disclosure of confidential information is a criminal offense. (Legal Issues module, Chapter 4, page
4-6)
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
15. The types of sampling which the inspector may undertake at the facility is determined by the terms and conditions
of the permit. (Legal Issues module, Chapter 5, page 5-2)
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
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UNIT 2 INSPECTION PROCEDURES
EXERCISE 2-2 ENTERING THE FACILITY 45 MINUTES
Specific procedures for entering a facility have been established and must be followed by inspectors at all times.
It is imperative that inspectors understand these procedures and their legal ramifications. Inspectors should be
aware that enforcement proceedings against a facility may be hindered if inspectors fail to follow required
procedures. This exercise focuses on entering a facility to conduct an inspection.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 2B and Appendix C of the Manual and Chapters 6 and 7 of the NPDES Compliance Monitoring
Inspector Training Legal Issues module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Describe the legal authority for an inspector's entry into a facility. (Manual, Chapter 2B, page 2-9)
2. State when and why an inspector's credentials need to be presented to facility officials. (Manual, Chapter 2B, page
2-9; Legal Issues module, Chapter 6, page 6-1)
3. Explain how an inspector might overcome initial reluctance on the part of a facility official to give consent to an
inspector. (Manual, Chapter 2B, page 2-10; Legal Issues module, Chapter 6, page 6-3)
4. Generally, inspections must occur during a facility's business hours. (Legal Issues module, Chapter 6, page 6-1)
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
5. If the facility refuses entry to an inspector, it becomes subject to civil penalties for violating its permit. (Legal
Issues module, Chapter 6, page 6-3)
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
6. Summarize the procedures to be followed if entry to a facility is denied. (Manual, Chapter 2B, page 2-11; Legal
Issues module, Chapter 6, page 6-3)
7. List two things an inspector should NEVER do if entry is denied. (Manual, Chapter 2B, pages 2-11 through 2-12;
Legal Issues module, Chapter 6, page 6-3)
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INSPECTION PROCEDURES UNIT 2
a.
b.
8. Once consent is given, it cannot be withdrawn, and an inspector does not have to halt an inspection. (Manual,
Chapter 2B, page 2-12; Legal Issues module, Chapter 6, page 6-3)
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
9. Describe the actions that an inspector should take if consent to conduct a facility inspection is withdrawn during
such an inspection. (Manual, Chapter 2B, page 2-12)
10
i. Explain the purpose of a warrant. (Manual, Chapter 2B, page 2-12; Legal Issues module, Chapter 7, page 7-1)
11. List the three grounds for obtaining a search warrant are. (Legal Issues module, Chapter 7, page 7-1)
a.
b.
12. To obtain a search warrant, an , indicating the grounds for issuance of the warrant, will also have
to be signed. (Legal Issues module, Chapter 7, page 7-3)
13. A criminal conviction requires the permitting authority to demonstrate evidence which is . (Legal
Issues module, Chapter 7, page 7-6)
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UNIT 2 INSPECTION PROCEDURES
EXERCISE 2-3 CONDUCTING THE OPENING CONFERENCE 15 MINUTES
The intent of an opening conference is to provide facility officials with a clear understanding of the authority,
purpose, and scope of the inspection to be conducted. The opening conference also provides the inspector with the
opportunity to carry out administrative duties. This exercise focuses on the components of an inspection's opening
conference.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 2C of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List three considerations that should be discussed during an opening conference to prevent misunderstandings and
assist facility personnel during an inspection. (Manual, Chapter 2C, pages 2-13 through 2-15)
b.
c.
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INSPECTION PROCEDURES UNIT 2
EXERCISE 2-4 DOCUMENTATION 2 HOURS
One basic responsibility of an inspector is documentation of the actual conditions existing at the time of the
inspection. Documentation is the basis on which EPA builds a case to prosecute violations of the CWA. It is
imperative that all documentation be developed in accordance with established procedures to ensure its accuracy
and objectivity. This exercise focuses on the components of documenting an inspection.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 2D of the Manual and Chapters 8 through 12 of the NPDES Compliance Monitoring Inspector
Training Legal Issues module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Explain the purpose of the field notebook and list the types of information to be entered in it. (Manual, Chapter
2D, pages 2-17 through 2-18)
2. Summarize the procedures for documenting a suspected violation by means of the items listed below. (Manual,
Chapter 2D, pages 2-18 through 2-22; Legal Issues module, Chapter 8, pages 8-1 through 8-2)
a. Statement from witnesses
b. Photographs
c. Video tapes
d. Drawings and maps
e. Printed matter
f. Mechanical recordings
3. Describe standard procedures for copying and identifying records. (Manual, Chapter 2D, pages 2-22 through 2-24)
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UNIT 2 INSPECTION PROCEDURES
4. Use of documentation as evidence in court is one reason why standard procedures are important when documenting
inspection findings. Assume you are called to the witness stand to testify regarding an inspection conducted the
previous year and are asked to identify a particular record. Describe how you would prove when, why, and by
whom the record was examined. (Manual, Chapter 2D, pages 2-22 through 2-24)
5. Describe how information can be claimed as confidential by the permittee. (Manual, Chapter 2D, page 2-24)
6. Explain what security measures should be taken to safeguard inspection data or information that a permittee
satisfactorily claims as confidential. (Manual, Chapter 2D, page 2-25)
7. Explain the policies regarding the discussion of deficiencies and violations identified during an inspection with
facility officials. (Manual, Chapter 2D, page 2-24)
8. Log books can be used to refresh the inspector's memory in the event s/he is called on to be a witness in an
enforcement action. (Legal Issues module, Chapter 10, page 10-3)
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
9. If the inspector believes s/he has made an error in testifying, the error should be announced or corrected as soon
as possible. (Legal Issues module, Chapter 10, page 10-3)
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
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INSPECTION PROCEDURES UNIT 2
EXERCISE 2-5 CONDUCTING THE CLOSING CONFERENCE 15 MINUTES
A final meeting with facility officials will enable the inspector to "wrap up" the inspection and will allow questions
to be answered and information gaps to be closed. This exercise focuses on the components of an inspection's closing
conference.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 2E and Appendix D of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List two topics an inspector should generally refrain from discussing with facility officials. (Manual, Chapter 2E,
page 2-27)
b.
2. Explain the purpose of a Deficiency Notice. (Manual, Chapter 2E, pages 2-27 through 2-28)
3. List five areas of a permittee's self-monitoring program that an inspector may address in a Deficiency Notice if
problems are identified during an inspection. (Manual, Chapter 2E, page 2-28)
a.
b.
c.
d.
e.
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UNIT 2 INSPECTION PROCEDURES
EXERCISE 2-6 PREPARING THE INSPECTION REPORT 30 MINUTES
Information gathered during an inspection must be organized and arranged in a manner that will allow case
proceedings personnel to develop a sound evidence package. The inspection report, if properly prepared, will serve
as the basis for this evidence. This exercise focuses on how to prepare an inspection report.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 2F and Appendix E of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. State the objective of an inspection report. (Manual, Chapter 2F, page 2-29)
2. List the four basic elements of an inspection report. (Manual, Chapter 2F, page 2-30)
a.
b.
c.
d.
3. Describe the purpose of a narrative report and the steps that should be followed to prepare a narrative report.
(Manual, Chapter 2F, pages 2-30 through 2-31)
4. Explain the inspector's responsibility relative to the Permit Compliance System. (Manual, Chapter 2F, page 2-31)
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INSPECTION PROCEDURES UNIT 2
UNIT 2 EXAM 30 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time limit listed above.
3. Verify the answers with your instructor.
4. Correct any errors and clarify problems or questions before proceeding to Unit 3.
Exam Questions
1. Official credentials must always be presented whether or not identification is requested by facility officials.
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
2. Authority to inspect under the CWA is granted by Section 304.
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
3. An inspector must secure the expressed consent of the agent in charge of the facility before entering.
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
4. If entry to a facility is denied for any reason, or if consent to inspect is withdrawn during an inspection, the
inspector should follow the denial of entry procedures which state that the inspector:
a. Should talk with officials to see if obstacles (such as misunderstandings) can be overcome
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
b. May suggest that facility officials contact their attorneys to clarify the situation
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
c. Should explain to facility officials the penalties under the CWA regarding refusal to allow entry
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
d. Should write down all observations regarding the incident, including any reasonable suspicions about the reasons
for denial of entry
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
5. Once an inspector is granted access to the facility, s/he, without additional consent from facility officials, has the
authority to:
a. Observe the source of discharges
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
b. Sample the effluent
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
c. Read and copy facility records
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UNIT 2 INSPECTION PROCEDURES
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
d. Inspect the monitoring equipment and observe self-monitoring procedures
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
6. List five types of information about the facility the inspector should obtain prior to an inspection.
a.
b.
c.
d.
e.
7. Describe the legal requirement an inspector must meet immediately on arrival at the facility.
8. What information should be recorded in the inspector's field notebook? (Circle correct answer.)
a. Conditions and practices observed during the inspection
b. Procedures followed by the inspector relating to all inspection activities
c. Listing of documents and samples taken by the inspector
d. Unusual conditions or practices observed by the inspector
e. General facility information
f. All of the above.
9. Of the following two items, which one best illustrates the type of information that should be included in a statement
used to document an alleged violation? (Circle correct answer.)
a. "It's common knowledge that they're dumping toxic chemicals illegally. You can see the trucks going by every
day."
b. "My boss told me to take a load of drums and keep them out in the back. Some of the drums were marked
"hazardous1."
Explain why.
10. Describe how photographs taken during an inspection should be identified.
11. Specific procedures have been developed to ensure that all inspection data received as confidential are protected
while in the custody of the inspector. Which of the following activities are not in accordance with these procedures
for handling confidential inspection data? (Circle the correct answer.)
a. Leaving inspection data in a locked motel room
b. Reviewing inspection data in the inspector's automobile
c. Reviewing inspection data in the presence of other inspectors
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INSPECTION PROCEDURES UNIT 2
d. Carrying inspection data while inspecting another facility
e. Locking physical samples in the inspector's automobile
f. All of the above.
12. The inspection report is a comprehensive collection of information designed to support enforcement personnel in
preparing for legal action. The information in the report must, above all, be complete and accurate. List three
other requirements of an inspection report.
a.
b.
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RECORD KEEPING AND REPORTING UNIT 3
UNIT THREE
DOCUMENTATION/RECORD KEEPING AND REPORTING
The NPDES permit program requires permittees to maintain records and report periodically on the quantity and
character of the waste in their wastestreams. Section 308 of the CWA authorizes inspection of required records and
reports. The NPDES inspector must be familiar with the purpose of, and procedures for, inspecting records. Unit Three
is based on Chapter 3 of the Manual. The unit is comprised of two exercises:
• Inspection authority and evaluation procedures for facility record reviews
• Summary/review (optional).
EXERCISE 3-1 INSPECTION AUTHORITY AND EVALUATION 1 HOUR
PROCEDURES FOR FACILITY RECORD REVIEWS
A review of a facility's records determines whether record-keeping and reporting requirements stipulated in the
permit are being met. This review is an important part of an NPDES inspection. Careful examination of the data
often indicate violations of record-keeping and reporting requirements as well as of other permit violations. This
exercise focuses on inspection authorities and evaluation procedures for facility record reviews.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 3 of the Manual and watch the video Conducting a Records Inspection.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems your instructor. Do not proceed until you have mastered the
material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. State the primary objective of a records inspection. (Manual, Chapter 3A, page 3-1, Video)
2. A permittee's required recordkeeping requirements are contained in its . (Manual,
Chapter 3B, page 3-3; Video)
3. As part of pre-inspection preparation, the inspector should review the facility's to
determine the facility's compliance history and to detect irregularities in sampling results. (Video)
4. List three items contained in a facility's permit that should be verified during the opening conference or walk-
through inspection. (Manual, Chapter 3B, page 3-3)
a.
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UNIT 3 RECORD KEEPING AND REPORTING
List at least five types of data or records that should be reviewed during the inspection to ensure retention for the
minimum required period of time. (Manual, Chapter 3B, pages 3-3 through 3-4; Video)
List four items the inspector should verify when reviewing sampling and analytical data to ensure that the facility
followed proper procedures. (Video)
a.
b.
c.
d.
7. To identify any discrepancies or errors in reporting sampling and analytical data, the inspector should compare
results in the DMRs to the facility's . (Video)
8. Explain when a compliance schedule status review should be conducted, and provide at least three reasons why it
should be conducted. (Manual, Chapter 3B, pages 3-5 through 3-6)
a.
b.
c.
9. Summarize (for each of the following components) the elements that should be reviewed by an inspector during
evaluation of a permittee's ability to meet its compliance schedule deadline. (Manual, Chapter 3B, pages 3-6
through 3-7)
a. Construction progress
b. Construction contract and equipment orders
c. Authorization and financing
d. Attainment of operational status
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RECORD KEEPING AND REPORTING UNIT 3
10. Summarize the procedures for conducting a review of POTW pretreatment program requirements. (Manual,
Chapter 3B, pages 3-7 through 3-8)
11. Describe when an in-depth investigation of permittee records should be conducted. (Manual, Chapter 3B, page 3-8
12. List at least five procedures that should be followed while conducting an in-depth investigation. (Manual, Chapter
3B, pages 3-8 through 3-9)
a.
b.
c.
d.
e.
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UNIT 3 RECORD KEEPING AND REPORTING
EXERCISE 3-2 SUMMARY/REVIEW (OPTIONAL) 15 MINUTES
This is an optional exercise which summarizes and reviews Chapter 3 of the Manual on record-keeping and
reporting.
1. Read the statements below describing a situation an inspector may face during an inspection. In the space
provided, respond to each statement, explaining how you would proceed to evaluate and document the situation.
Refer to Chapter 3 of the Manual as necessary.
2. Discuss any questions or problems with your instructor. Do not proceed until you have mastered the material
in this exercise.
Study Checklist At the end of this exercise, you should be able to respond to these situations:
1. During an inspection of a permittee's records, it is discovered that records of laboratory equipment calibration,
required by the permit, have not been kept for the past 6 months. Respond to this situation. (Manual, Chapter 3B)
2. During a review of POTW pretreatment requirements, the POTW is unable to produce a list of contributory
Industrial Users (IDs). Respond to this situation. (Manual, Chapter 3B)
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RECORD KEEPING AND REPORTING UNIT 3
UNIT 3 EXAM 15 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time limit listed above.
3. Verify the answers with your instructor.
4. Correct any errors and clarify questions or problems before proceeding to Unit 4.
Exam Questions
1. List at least five types of records generally verified during a facility inspection.
b.
c.
d.
e.
2. Authority to require that certain records be kept by permittees comes from the CWA in Sections
3. Routine record-keeping and reporting evaluations are conducted at all permittee facilities. Provide an example of
when an in-depth investigation of records would be warranted.
4. List three actions of a permittee's compliance schedule covered by compliance schedule status reviews.
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FACILITY SITE REVIEW UNIT 4
UNIT FOUR
FACILITY SITE REVIEW
The objective of a facility site review is to examine the permittee's physical and operational plant functions for
compliance with permit conditions and effluent limitations. To carry out this responsibility, inspectors must have a
thorough understanding of each treatment process in the facility and how each process fits into the overall treatment
scheme. The success of a facility site review will depend on the inspector's ability to identify problem areas that will
affect the performance of the treatment facility. Unit Four corresponds to Chapter 4 of the Manual and several other
EPA documents. Topics covered in the three exercises contained in this unit include:
• Physical inspection of the facility
• Operation and Maintenance (O&M) evaluation
• Summary of treatment units and operations that should be inspected (optional).
EXERCISE 4-1 PHYSICAL INSPECTION OF THE FACILITY 1 HOUR
To carry out their duties effectively, inspectors must be thoroughly familiar with the physical aspects of a treatment
facility. This exercise is designed to review the primary indications of noncompliance at a treatment facility.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapters 4A and 4B of the Manual. For additional information, review EPA's 1978 Field Manual for
Performance Evaluation and Trouble-Shooting at Municipal Wastewater Treatment Facilities, MO #16, EPA
430/9-78-001.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List four objectives of the facility site review. (Manual, Chapter 4A, page 4-1)
a.
d.
2. List four areas that should be covered in the walk-through. (Manual, Chapter 4B, page 4-3)
b.
c.
d.
3. List five problem indicators associated with chemical treatment units. (Manual, Chapter 4B, page 4-13)
a.
b.
c.
d.
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UNIT 4 FACILITY SITE REVIEW
e.
4. List five problem indicators associated with primary clarifiers and five problem indicators associated with
secondary clarifiers. (Manual, Chapter 4B, pages 4-6 and 4-7)
Primary Clarifiers Secondary Clarifiers
a. a.
b. b.
c. c.
d. d.
e. e.
5. List four problem indicators associated with trickling filters. (Manual, Chapter 4B, page 4-6)
a.
b.
c.
d.
6. List five problem indicators associated with a filtration unit (i.e., an advanced physical treatment system).
(Manual, Chapter 4B, page 4-8)
a.
b.
c.
d.
e.
7. List four problem indicators for chlorination units and four problem indicators for dechlorination units. (Manual,
Chapter 4B, page 4-9)
Chlorination Units Dechlorination Units
a. a.
b. b.
c. c.
d. d.
8. List three problem indicators for polishing ponds or tanks. (Manual, Chapter 4B, page 4-12)
a.
b.
c.
9. List three general problem indicators that may be found during an inspection of sludge-handling facilities and four
problem indicators that may be identified during inspection of sludge-disposal processes. (Manual, Chapter 4B,
pages 4-9 through 4-12)
Sludge Handling Sludge Disposal
a. a.
b. b.
c. c.
d.
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FACILITY SITE REVIEW UNIT 4
10. Discuss potential production changes at an industrial facility which should be evaluated or verified and documented
by an inspector. (Manual, Chapter 4B, pages 4-13 through 4-14)
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UNIT 4 FACILITY SITE REVIEW
EXERCISE 4-2 O&M EVALUATION 30 MINUTES
Operating factors that may affect plant performance range from the knowledge and skill of the operator to physical
deficiencies in the equipment. This exercise will review the plant O&M functions that an inspector should cover.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 4C of the Manual. For additional information, review EPA's 1973 Maintenance Management
Systems for Municipal Wastewater Facilities, EPA 430/9-74-004.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List the five areas that must be evaluated by an inspector during a review of operation functions. (Manual, Chapter
4C, page 4-15)
6.
b.
c.
d.
e.
2. Discuss the information that should be available to the inspector while evaluating the operating policy and
procedures of a facility. (Manual, Chapter 4C, page 4-15)
3. Identify the facility staff members that should be interviewed by the inspector to identify staffing problems.
(Manual, Chapter 4C, page 4-15)
4. Describe Occupational Safety and Health Administration Right-to-Know laws. (Manual, Chapter 4C, page 4-16)
5. Discuss the factors an inspector should consider when evaluating management controls. (Manual, Chapter 4C, page
4-16)
Explain how corrective- and preventive-maintenance programs relate to efficient plant functions and why this is
important to an inspector. (Manual, Chapter 4C, pages 4-16 through 4-17)
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FACILITY SITE REVIEW UNIT 4
7. List three topics of primary concern to an inspector during a maintenance evaluation. (Manual, Chapter 4C, page
4-17)
a.
b.
c.
8. Describe the elements of a maintenance cost-control system. (Manual, Chapter 4C, page 4-17)
9. Describe the elements of the management-control system for plant maintenance that an inspector should evaluate.
(Manual, Chapter 4C, pages 4-23 through 4-24)
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UNIT 4 FACILITY SITE REVIEW
EXERCISE 4-3 SUMMARY OF TREATMENT UNITS AND OPERATIONS 3 HOURS
THAT SHOULD BE INSPECTED (OPTIONAL)
This summary exercise focuses on the types of treatment units and operations found at wastewater treatment
facilities.
1. Obtain an example inspection plan and a description of a wastewater treatment facility from your instructor.
2. Develop a written plan for the inspection of this facility. It should detail the objectives and information to be
collected during the inspection. The plan should list treatment units and O&M functions that should be
inspected. For each unit or function you identify, describe how you plan to evaluate compliance (Manual,
Chapter 4).
3. Discuss the plan with your instructor. If an observation inspection can be arranged, use the inspection to
clarify questions or problems you have regarding the facility site review.
4. Discuss any questions or problems with your instructor. Do not proceed until you have mastered the material
in this exercise.
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FACILITY SITE REVIEW UNIT 4
UNIT 4 EXAM 30 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time limit listed above.
3. Verify the answers with your instructor.
4. Correct any errors and clarify questions or problems before proceeding to Unit 5.
Exam Questions
1. For each of the areas listed below, list a minimum of three indicators of treatment process problems.
a. Flow indicators
b. Unusual waste
2. Discuss the impact of production changes and describe the areas related to production changes the inspector should
investigate relating to production changes.
3. List three important areas to be addressed during an operation evaluation. For each area, list three questions that
should be asked by the inspector.
b.
4. List three important areas to be addressed during a maintenance evaluation. For each area, list three questions
that should be asked by the inspector.
a.
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UNIT 4 FACILITY SITE REVIEW
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SAMPLING UNIT 5
UNIT FIVE
SAMPLING
NPDES permittees are required to sample their wastewater as part of the NPDES Compliance Monitoring
Program. The inspector's role is to both evaluate the permittee's self-monitoring compliance program and verify those
program data on overall permit compliance by sampling the wastewater. To fulfill this two-fold responsibility, the
inspector must know:
• Permittee sampling requirements
• Sampling procedures and techniques.
These topics correspond to Chapter 5 of the Manual, EPA's 1990 NPDES Compliance Monitoring Inspector Training
Sampling module, and several other EPA documents. They are addressed in the two exercises included in this unit.
EXERCISE 5-1 EVALUATION OF PERMITTEE SAMPLING 30 MINUTES
PROGRAM AND COMPLIANCE SAMPLING
When evaluating a permittee's sampling program, the NPDES inspector must be cognizant of the effluent limitations
and monitoring requirements of the permit. The objectives and requirements for inspecting sampling programs are
covered in this exercise.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 5A of the Manual and Chapter 1 of the NPDES Compliance Monitoring Inspector Training
Sampling module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List the five objectives of sampling conducted by inspectors. (Manual, Chapter 5A, page 5-1; Sampling module,
Chapter 1, page 1-3)
b.
c.
d.
e.
2. List six areas to assess in evaluating sampling procedures. (Manual, Chapter 5A, page 5-2; Sampling module,
Chapter 1, pages 1-3 through 1-4)
c.
d.
e.
f.
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UNIT 5
SAMPLING
3. The inspector does not have to evaluate sampling procedures of a POTW for SIUs that discharge to the POTW.
(Manual, Chapter 5A, page 5-2)
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
EXERCISE 5-2
SAMPLING PROCEDURES AND TECHNIQUES
4 HOURS
30 MINUTES
By collecting samples, the inspector can verify (firsthand) a permittee's compliance with effluent limitations and
other permit parameters, further evaluate the permittee's self-monitoring program, and support enforcement actions
or permit reissuance or revision. This exercise reviews general sampling methods and associated procedures.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 5B and Appendix F of the Manual and Chapters 2, 3, 4, 6, and 7 of the NPDES Compliance
Monitoring Inspector Training Sampling module. Watch the video Sampling Wastewater at a Wastewater
Treatment Plant. For additional information, refer to these two EPA handbooks: EPA's 1979 Methods for
Chemical Analysis of Water and Wastes, EPA-600/4-79-020 and EPA's 1982 Handbook for Sampling and Sample
Preservation of Water and Wastewater, EPA-600/4-82-029.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
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SAMPLING UNIT 5
Study Checklist At the end of this exercise, you should be able to:
1. Summarize the main features of a representative site for collecting samples. (Manual, Chapter 5B, pages 5-3
through 5-4; Sampling module, Chapter 2, pages 2-5 through 2-6; Video)
a. Influent samples
b. Effluent samples
2. Prior to going onsite to conduct sampling, the inspector should develop a that
identifies sampling procedures to be followed. (Video)
3. List and describe the two primary types of samples that can be collected. (Manual, Chapter 5B, page 5-5; Sampling
module, Chapter 2, pages 2-8 through 2-10)
b.
4. Describe the parameters for which grab samples should be taken. (Manual, Chapter 5B, page 5-5; Sampling
module, Chapter 2, page 2-8)
5. List the four methods for compositing samples. (Manual, Chapter 5B, pages 5-5 through 5-6; Sampling module,
Chapter 2, pages 2-9 through 2-10)
a.
b.
c.
d.
6. Required sample containers, preservation methods, and maximum allowable holding times are contained in
. (Manual, Chapter 5B, pages 5-6 through 5-8; Video)
7. Indicate how to determine the appropriate sample volume that should be collected. (Manual, Chapter 5B, page 5-6;
Sampling module, Chapter 2, page 2-14; Video)
8. Discuss the types of sample containers appropriate for collecting samples to be analyzed for specific constituents
or classes of pollutants. (Manual, Chapter 5B, page 5-6; Sampling module, Chapter 2, pages 2-6 through 2-7; Video)
9. Describe how a bacteriological sample should be collected. Explain why. (Sampling module, Chapter 2, pages
2-20 through 2-21; Video)
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UNIT 5 SAMPLING
10. Indicate the type of container oil and grease samples should be taken in. (Manual, Chapter 5B, page 5-6; Sampling
module, Chapter 2, page 2-22; Video)
11. Describe the type of sample container used for volatile organics and indicate how a sample is collected. (Sampling
module, Chapter 2, page 2-22)
12. List two types of blank samples that a sampler may need to take in the field. (Manual, Chapter 5B, page 5-9;
Sampling module, Chapter 6, pages 6-3 through 6-4; Video)
a.
b.
13. Describe what an equipment blank is and what it is used for. (Video)
14. List five examples of the kinds of information that should be recorded to identify a sample. (Manual, Chapter 5B,
page 5-7; Sampling module, Chapter 2, page 2-16)
a.
b.
c.
d.
e.
15. Identify the proper container, preservative, and maximum holding time for testing wastewater alkalinity. (Manual,
Chapter 5B, Table 5-3; Sampling module, Appendix E)
16. List three standard procedures used to preserve samples. (Manual, Chapter 5B, pages 5-7 through 5-8; Sampling
module, Chapter 2, page 2-15; Video):
a.
b.
c.
17. Describe the purpose and importance of chain-of-custody procedures and records when transferring and handling
samples. (Manual, Chapter 5B, page 5-8; Video)
NPDES INSPECTION MANUAL SEPTEMBER 1995
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SAMPLING UNIT 5
UNIT 5 EXAM 45 MINUTES
Instructions
1. Complete this exam without referring to text or notes.
2. Do not exceed the time limit listed above.
3. Verify the answers with your instructor.
4. Correct any errors and clarify problems or questions before proceeding to Unit 6.
Exam Questions
1. The inspector (should/should not) be able to determine whether or not the sampling site specified in the permit is
adequate for the collection of a representative sample. (Circle the correct answer.)
2. Identify the citation to the CFR which specifies required sample containers, preservation techniques, and maximum
allowable holding times to be used in wastewater analysis.
3. List three preferred influent sampling points for raw wastewater.
b.
c.
4. List two situations when collection of a grab sample is appropriate, and two situations when collection of a
composite sample is appropriate.
Grab Composite
5. Identify the type of sample to be collected for determining pH.
6. List at least six items that must be recorded on the label and/or data sheet to accurately identify a sample.
a.
b.
c.
d.
e.
f.
7. Summarize the sample types listed below and explain the objectives of each in terms of their usefulness.
a. Duplicate samples
•
•
b. Split samples
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UNIT 5 SAMPLING
c. Spiked samples
d. Sample preservative blanks
8. Explain the significance of a chain-of-custody record in the event that a facility is in violation of its permit
requirements.
9. Indicate who must fill out the chain-of-custody record.
10. Describe the parameters for which grab samples are appropriate.
NPDES INSPECTION MANUAL SEPTEMBER 1995
STUDENT'S GUIDE 5-6
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FLOW MEASUREMENT UNIT 6
UNIT SIX
FLOW MEASUREMENT
NPDES permits require facilities to accurately measure, record, and report the quantity of wastewater discharged.
Flow measurement by a permittee provides information on the operation, performance, and cost of wastewater treatment
and data for long-term plant production capacity in conjunction with treatment capacity. Evaluations of a permittee's
compliance with flow-measurement requirements involve inspection of a facility's flow- measurement devices, data
handling and reporting procedures, and QC measures, as well as independent flow measurement by inspectors. Topics
addressed in this unit and corresponding to Chapter 6 and Appendix G of the Manual and EPA's 1990 NPDES Compliance
Monitoring Inspector Training Sampling module include:
• Evaluation of a permittee's flow-measurement equipment and procedures
• Flow-measurement methods
• Flow-measurement compliance inspection procedures.
EXERCISE 6-1 EVALUATION OF A PERMITTEE'S 1 HOUR
FLOW-MEASUREMENT EQUIPMENT AND PROCEDURES
To accurately evaluate a permittee's flow-measurement program, the inspector must be familiar with flow-
measurement devices, data-recording concerns, and QC needs. This exercise provides an introduction to each of
these concerns.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 6A of the Manual and Chapter 5 of the NPDES Compliance Monitoring Inspector Training
Sampling module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Differentiate between closed-channel flow and open-channel flow. (Manual, Chapter 6A, page 6-1; Sampling
module, Chapter 5, pages 5-1 and 5-7)
2. Differentiate between primary and secondary flow-measurement devices and give an example of each. (Manual,
Chapter 6A, pages 6-1 through 6-2; Sampling module, Chapter 5, pages 5-1 through 5-7)
3. List five conditions that inspectors should evaluate while inspecting flow-measurement devices installed by a
permittee for self-monitoring purposes. (Manual, Chapter 6A, pages 6-2 through 6-3)
a.
b.
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UNIT 6 FLOW MEASUREMENT
c.
d.
e.
4. Describe the information that should be maintained by a permittee to illustrate thorough record-keeping practices
for flow. (Manual, Chapter 6A, page 6-3)
5. List four issues integral to QC that should be evaluated by an inspector. (Manual, Chapter 6A, page 6-4)
a.
b.
c.
d.
NPDES INSPECTION MANUAL SEPTEMBER 1995
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FLOW MEASUREMENT UNIT 6
EXERCISE 6-2 FLOW-MEASUREMENT METHODS 1 HOUR
This exercise introduces the student to the basics of flow measurement (including hydraulic calculations and the
components and use of various flow-measurement devices).
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Appendix G of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Describe the components of a typical continuous flow-measurement system. (Manual, Appendix G, page G-l)
2. Discuss the difference between continuous and instantaneous flow measurement. (Manual, Appendix G, pages G-l
through G-2)
3. List four variations of the sharp-crested weir. (Manual, Appendix G, Figure G-2; Sampling module, Chapter 5,
page 5-4)
a.
b.
c.
d.
4. Summarize the operating principles on which the primary devices listed below are based. (Manual, Appendix G,
pages G-2 through G-5; Sampling module, Chapter 5, pages 5-2 through 5-9)
a. Weirs
b. Parshall flume
c. Palmer-Bowlus flume
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UNIT 6 FLOW MEASUREMENT
d. Venturi meter
e. Electromagnetic flow meter
f. Propeller meter
5. Define the purpose of secondary flow-measurement devices. Define the two classes of secondary devices and
provide examples of each. (Manual, Appendix G, page G-5; Sampling module, Chapter 5, page 5-7)
6. Describe the advantages and disadvantages of using pressure-bulb-measuring devices. (Manual, Appendix G, Table
G-9)
7. Explain why flow-measurement using pump data is not normally used for NPDES permit compliance evaluation.
(Manual, Appendix G, page G-6)
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FLOW MEASUREMENT UNIT 6
EXERCISE 6-3 FLOW-MEASUREMENT COMPLIANCE 1 HOUR
INSPECTION PROCEDURES
A review of a permittee's flow-measurement devices and techniques and of the data collected should indicate
whether or not the permittee is accurately monitoring and reporting the type and amount of wastewater generated
and discharged. This exercise introduces procedures for inspecting various flow-measurement devices, measuring
flow using common, permanent, and portable systems, and evaluating flow data.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 6B of the Manual and watch the video Inspecting a Parshall Flume.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List the four steps that an inspector should follow to evaluate flow-measurement systems. (Manual, Chapter 6B,
page 6-6; Video)
b.
c.
d.
2. List two examples of when the use of a portable flow meter would be appropriate. (Manual, Chapter 6B, page 6-5)
b.
3. List four items that an inspector should consider during evaluation of a permittee's flow-measurement system.
(Manual, Chapter 6B, page 6-5)
a.
b.
c.
d.
4. List four common sources of errors in the use of primary flow-measuring devices (sharp-crested weirs and Parshall
flumes) and four sources of errors in the use of secondary devices. (Manual, Chapter 6B, page 6-6 and pages 6-9
and 6-10)
Primary Devices Secondary Devices
a. a.
b. b.
c. c.
d. d.
5. Describe how to inspect sharp-crested weirs. (Manual, Chapter 6B, page 6-7)
6. Describe the proper location of a Parshall flume. (Manual, Chapter 6B, page 6-8; Video)
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UNIT 6 FLOW MEASUREMENT
7. Describe how to inspect a Parshall flume. (Manual, Chapter 6B, page 6-8; Video)
Describe how to inspect the discharge (downstream channel) of a Parshall flume. (Manual, Chapter 6B, page 6-8;
Video)
9. Describe the procedures used to measure flow under free-flow conditions. (Manual, Chapter 6B, page 6-10)
10. Describe how to verify that a flow totalizer is correctly calibrated. (Manual, Chapter 6B, page 6-12)
NPDES INSPECTION MANUAL SEPTEMBER 1995
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FLOW MEASUREMENT UNIT 6
UNIT 6 EXAM 30 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time limit noted above.
3. Verify the answers with your instructor.
4. Correct any errors and clarify problems or questions before proceeding to Unit 7.
Exam Questions
1. The permittee may be required to retain flow-measurement records for a minimum of 2 years.
TRUE \3 FALSE \3 (Check one. If the statement is false, make the necessary changes to correct it.)
2. The inspector should determine whether primary and secondary flow devices are adequate for measuring normal
flow as well as for measuring maximum expected flow.
TRUE \J FALSE \J (Check one. If the statement is false, make the necessary changes to correct it.)
3. A flow-measurement system must be able to measure within ±10 percent to be considered accurate.
TRUE \3 FALSE \3 (Check one. If the statement is false, make the necessary changes to correct it.)
4. The permittee may choose an appropriate flow-measurement site regardless of permit specifications.
TRUE \3 FALSE \3 (Check one. If the statement is false, make the necessary changes to correct it.)
5. Describe the circumstances under which the inspector would use a portable flow sensor and recorder rather than
those installed in the facility being inspected.
6. List three factors the inspector should consider when evaluating a Parshall flume.
b.
c.
7. The Venturi meter measures differences in between the inlet section and the throat of the meter.
8. Discuss the advantages and disadvantages of using electromagnetic flow meters.
9. Explain how secondary devices are used within a flow-measurement system.
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UNIT 6 FLOW MEASUREMENT
10. List the two broad classes of secondary devices.
a.
b.
NPDES INSPECTION MANUAL SEPTEMBER 1995
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LABORATORY PROCEDURES ASSURANCE UNIT 7
UNIT SEVEN
LABORATORY PROCEDURES QUALITY ASSURANCE
The analytical laboratory has the primary responsibility for providing the data necessary to determine a permittee's
compliance with NPDES standards and requirements. These data must be accurate and reliable in their description of
the characteristics and concentrations of constituents appearing in the test samples. The laboratory QA program ensures
accurate data result from the activities of the analytical laboratory. Topics covered in the exercises in this unit (which
correspond to Chapter 7 of the Manual and EPA's 1990 NPDES Compliance Monitoring Inspector Training Laboratory
Analysis module) include:
• Objectives and requirements
• Sample handling procedures
• Laboratory analyses techniques evaluation
• QA and QC.
EXERCISE 7-1 OBJECTIVES AND REQUIREMENTS 15 MINUTES
Reviews of sampling, analytical, and laboratory QA techniques are components of many NPDES inspections. This
exercise is intended to provide an introduction to laboratory QA requirements and procedures.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 7A of the Manual and Chapter 1 of the NPDES Compliance Monitoring Inspector Training
Laboratory Analysis module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List two primary functions of the laboratory QA program. (Manual, Chapter 7A, page 7-1)
a.
b.
2. Define QA. (Manual, Chapter 7A, page 7-1)
Describe activities for which QA measures are required. (Manual, Chapter 7A, page 7-1)
4. Describe items that should be included in a laboratory's QA/QC manual. (Manual, Chapter 7A, page 7-1)
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UNIT 7 LABORATORY PROCEDURES QUALITY ASSURANCE
5. Define QC. Indicate how QC is different from QA. (Manual, Chapter 7A, page 7-1)
6. Explain the purpose of the laboratory evaluation. (Laboratory Analysis module, Chapter 1, pages 1-2 through 1-3)
NPDES INSPECTION MANUAL SEPTEMBER 1995
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LABORATORY PROCEDURES ASSURANCE UNIT 7
EXERCISE 7-2 SAMPLE HANDLING PROCEDURES 15 MINUTES
Sample handling procedures are an important component of any monitoring program. To accurately assess the
adequacy of a laboratory's sample receipt and handling procedures, an inspector must be familiar with such
requirements. This exercise addresses sample handling procedures.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 7B of the Manual and Chapter 2 (Sections 2.1 through 2.4) of the NPDES Compliance Monitoring
Inspector Training Laboratory Analysis module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Explain why sample handling and control procedures are important to a permittee. (Manual, Chapter 7B, page 7-3;
Laboratory Analysis module, Chapter 2, page 2-9)
2. List five procedures that should be used by laboratory personnel and verified by an inspector. (Manual, Chapter
7B, page 7-3)
a.
b.
c.
d.
3. Describe the primary sources of information about a permittee and its compliance with the permit requirements.
(Laboratory Analysis module, Chapter 2, page 2-3)
EXERCISE 7-3 LABORATORY ANALYSES TECHNIQUES 45 MINUTES
EVALUATION
The use of uniform and standardized testing methodologies is critical in comparing or sharing data among
laboratories. In addition, maintenance of the laboratory's facilities and equipment is also important to laboratory
QA. This exercise addresses laboratory analyses techniques evaluation.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 7C of the Manual and Chapter 2 (Section 2.5) of the NPDES Compliance Monitoring Inspector
Training Laboratory Analysis module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
SEPTEMBER 1995 NPDES INSPECTION MANUAL
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UNIT 7 LABORATORY PROCEDURES QUALITY ASSURANCE
1. Identify the part and section of the CFR in which the approved analytical test procedures are prescribed. (Manual,
Chapter 7C, page 7-5; Laboratory Analysis module, Chapter 2, page 2-13)
2. List at least two publications in which approved 40 CFR Part 136 procedures are published. (Manual, Chapter 7C,
page 7-5; Laboratory Analysis module, Chapter 2, page 2-13)
a.
b.
3. Explain why it is important that a laboratory use approved, standardized analytical methods. (Manual, Chapter 7C,
page 7-5)
4. Identify the key to quality analytical performance. (Laboratory Analysis module, Chapter 2, page 2-14)
5. List four items that should be verified by an inspector while evaluating a laboratory's analytical procedures.
(Manual, Chapter 7C, pages 7-5 through 7-6)
a.
b.
c.
d.
6. List four items or services which affect the reliability of data that should be available in all laboratories. (Manual,
Chapter 7C, page 7-6)
a.
b.
c.
d.
7. List four procedures or conditions that should be verified by an inspector while evaluating a laboratory's storage
and preparation of reagents and standards. (Manual, Chapter 7C, pages 7-7 through 7-8)
a.
b.
c.
d.
8. Describe the procedures that should be observed when dealing with laboratory supplies that have a limited shelf
life. (Manual, Chapter 8C, page 8-7)
NPDES INSPECTION MANUAL SEPTEMBER 1995
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LABORATORY PROCEDURES ASSURANCE UNIT 7
EXERCISE 7-4 QA AND QC 1 HOUR
45 MINUTES
Laboratory control procedures are established to ensure high-quality analyses. The precision (reproduceability
among replicate observations) and accuracy (degree of difference between observed and actual values) of a
laboratory's findings are important factors in ensuring the quality of analytical results. This exercise summarizes
QA and QC procedures.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 7D of the Manual and Chapter 2 (Sections 2.6 through 2.7) of the NPDES Compliance Inspector
Training Laboratory Analysis module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List the four primary procedures used by laboratories to ensure high-quality analyses. (Manual, Chapter 7D, page
7-9)
a.
b.
c.
d.
2. Define the terms "precision" and "accuracy." (Manual, Chapter 7D, page 7-9; Laboratory Analysis module,
Chapter 2, page 2-22)
3. Explain how, when, and/or why each of the following items or processes is used to establish the precision or
accuracy of laboratory analytical procedures. (Manual, Chapter 7D, pages 7-9 through 7-10; Laboratory Analysis
module, Chapter 2, pages 2-24 through 2-29)
a. Control samples
b. Duplicate samples/analyses
c. Precision control charts
d. Spiked samples
e. Accuracy control charts
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UNIT 7 LABORATORY PROCEDURES QUALITY ASSURANCE
4. Explain how accuracy warning and control limits are established and when corrective actions should be taken with
respect to these limits. (Manual, Chapter 7D, pages 7-9 through 7-10; Laboratory Analysis module, Chapter 2,
pages 2-26 through 2-30)
5. List five procedures that should be used by analytical laboratories to record, process, and report data. (Manual,
Chapter 7D, pages 7-10 through 7-11)
a.
b.
c.
d.
e.
6. List five types of data that should be kept in a laboratory analyst's notebook. (Manual, Chapter 7D, page 7-11)
a.
b.
c.
d.
e.
7. Describe the skills required of professional laboratory personnel and laboratory assistants. (Manual, Chapter 7D,
page 7-11)
8. Explain the Discharge Monitoring Report Quality Assurance (DMR QA) Program. (Manual, Chapter 7D, page
7-12)
9. List three benefits or positive aspects of the DMR QA Program. (Manual, Chapter 7D, page 7-12)
a.
b.
10. Explain the interdependency of the NPDES inspection program and the DMR QA Program. (Manual, Chapter 7D,
page 7-13)
NPDES INSPECTION MANUAL SEPTEMBER 1995
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LABORATORY PROCEDURES ASSURANCE UNIT 7
UNIT 7 EXAM 15 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time limit listed above.
3. Verify the answers with your instructor.
4. Correct any errors and clarify questions or problems before proceeding to Unit!
Exam Questions
1. Define QA.
2. Define QC.
3. List the two reference books many standardized test procedures as promulgated under 40 CFR Part 136 are
published in.
b.
4. List four services that all laboratories should have on hand to ensure production of reliable data.
b.
c.
d.
5. Written schedules for required or recommended replacement, cleaning, checking, and/or adjustment of laboratory
instruments and equipment are not a concern to the inspector.
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
6. Working standards should be checked frequently to determine changes in or
7. percent of samples should be duplicated.
8. The upper and lower accuracy control limits are established at times the standard deviation above and
below the central line.
9. Explain when the laboratory should take corrective actions for precision control limits.
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UNIT 7 LABORATORY PROCEDURES QUALITY ASSURANCE
10. A laboratory does not need to have provisions for cross-checking calculations.
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
11. All incoming samples should be received by a custodian, who then signs the chain-of-custody record sheet
accompanying the samples and retains the sheet as a permanent record.
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
NPDES INSPECTION MANUAL SEPTEMBER 1995
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TOXICITY UNIT 8
UNIT EIGHT
TOXICITY
The inspector's responsibility during a biomonitoring inspection is to attempt to determine whether or not the
permittee's toxicity testing program meets the requirements of the permit. The inspector must be familiar with the
permittee's toxicity testing requirements as well as with toxicity sampling and monitoring procedures and any
modifications to those procedures.
Compliance Biomonitoring Inspections (CBI) (as opposed to biomonitoring inspections) involve evaluation of a
permittee's effluent through the inspecting agency's (i.e., EPA or the State) conduct of toxicity testing. The regulatory
agency or inspector may evaluate a permittee's effluent by conducting either onsite or offsite toxicity tests. To ensure
successful conduct of a CBI, the inspector must be knowledgeable of sample collection and handling procedures, use of
test organisms, facility/equipment needs, and toxicity testing procedures. Topics addressed in this unit (which correspond
to Chapter 8 of the Manual and EPA's 1990 NPDES Compliance Monitoring Inspector Training Biomonitoring module)
include:
• Objectives
• Requirements of WET testing
• Analysis of results.
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UNIT 8 TOXICITY
EXERCISE 8-1 OBJECTIVES 30 MINUTES
NPDES permits impose toxicity testing requirements as a means of assessing the quality or toxicity of a facility's
effluent. To effectively evaluate a permittee's self-monitoring program, the inspector must be familiar with toxicity
testing requirements and procedures. This exercise provides the inspector with an introduction to such information.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 8A of the Manual and Chapter 1 of the NPDES Compliance Monitoring Inspector Training
Biomonitoring module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List at least four objectives of a biomonitoring inspection. (Manual, Chapter 8A, page 8-1)
a.
c.
d.
2. Define toxicity. (Manual, Chapter 8A, page 8-1; Biomonitoring module, Chapter 1, page 1-3)
3. Explain how toxicity of a substance is measured. (Manual, Chapter 8A, page 8-1)
4. List five types of NPDES inspections which involve performing or evaluating whole effluent toxicity testing
(Manual, Chapter 8A, page 8-1; Biomonitoring module, Chapter 1, pages 1-3 through 1-4)
a.
b.
c.
d.
e.
NPDES INSPECTION MANUAL SEPTEMBER 1995
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TOXICITY UNIT 8
EXERCISE 8-2 REQUIREMENTS OF WET TESTING 3 HOURS
30 MINUTES
Inspectors must be familiar with the technical procedures to be followed when conducting effluent biomonitoring
or toxicity testing inspections. Procedures and standards exist for effluent and dilution water, test organisms, and
record-keeping and reporting. These issues are covered in this exercise.
1. Read through the study checklist. Test your background knowledge by responding to as many items as possible.
2. Read Chapter 8B and Appendix H of the Manual and Chapters 2 through 7 of the NPDES Compliance
Monitoring Inspector Training Biomonitoring module. Watch the video Conducting a Performance Audit
Inspection at a Facility Conducting Toxicity Testing.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Discuss the difference between acute and chronic toxicity test methods. (Manual, Chapter 8B, page 8-3;
Biomonitoring module, Chapter 2, page 2-3)
2. List five protocols or requirements for WET testing that are typically included in a facility's NPDES permit.
(Video)
a.
b.
c.
d.
e.
3. If an effluent sample is not to be used immediately, describe how it should be preserved. (Manual, Chapter
page 8-4; Biomonitoring module, Chapter 4, page 4-3)
4. Effluent samples must be used within hours of sampling. (Manual, Chapter 8B, page 8-4; Biomonitoring
module, Chapter 3, page 3-3)
5. If the D.O. in an effluent sample is not near saturation, the sample should be . (Video)
6. Discuss dilution water sources and how to determine which source should be used. (Manual, Chapter 8B, page 8-5;
Biomonitoring module, Chapter 5, pages 5-1 through 5-2)
7. Receiving water that is used as dilution water should be refrigerated if not used in a test within hours.
(Manual; Chapter 8B, Page 8-5; Biomonitoring module, Chapter 5, page 5-2)
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UNIT 8 TOXICITY
8. Describe problems that can be caused by not removing excess food. (Manual, Chapter 8B, page 8-7; Biomonitoring
module, Chapter 6, page 6-6)
9. If a laboratory cultures test organisms onsite, it may house the brood stock in the testing area. (Video)
TRUE \J FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
10. Adding dilution water to the water that organisms were raised in prior to a test is called .
(Biomonitoring module, Chapter 6, page 6-6)
11. The zero percent dilution (that is 0% effluent and 100 percent dilution water) is the .
(Video)
12. Plastic containers and tubing that are used in a toxicity test can be washed and used again. (Manual, Chapter 8B,
page 8-6; Biomonitoring module, Chapter 7, page 7-2)
TRUE \3 FALSE \3 (Check one. If the statement is false, make necessary changes to correct it.)
13. No materials containing , , , , and
should come into contact with any solution to be used in toxicity testing. (Manual, Chapter
8B, page 8-6; Biomonitoring module, Chapter 7, page 7-2)
14. What should be done with test results obtained when temperatures were outside ranges specified by the test
protocol? (Biomonitoring module, Chapter 7, page 7-3)
15. Dissolved oxygen should be above percent saturation for tests run at more than 20°C or above
percent saturation for tests run at below 20°C. (Manual, Chapter 8B, page 8-17;
Biomonitoring module, Chapter 7, page 7-4)
16. List the five areas or procedures that are generally covered during a PAI at a facility conducting toxicity testing.
(Video)
a.
b.
c.
d.
e.
17. List four test conditions that should be evaluated during an inspection of a laboratory conducting toxicity testing.
(Video)
a.
b.
c.
d.
18. In a test with a reference toxicant, what should be done with organisms whose responses are outside the limits
specified for that toxicant? (Biomonitoring module, Chapter 6, page 6-5)
NPDES INSPECTION MANUAL SEPTEMBER 1995
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TOXICITY UNIT 8
EXERCISE 8-3 ANALYSIS OF RESULTS 30 MINUTES
Inspectors should be able to analyze and interpret WET test results, including acceptable mortality in controls
and abnormalities in test data. Inspectors should also be familiar with the definitions in which test results are
expressed so that test results can be compared to permit limits. This exercise familiarizes the inspector with
this information.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 8C of the Manual, review Chapter 2 and read Chapter 8 of the NPDES Compliance
Monitoring Inspector Training Biomonitoring module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses made
in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you have mastered
the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Mortality in controls must be less than percent for acute tests and less than percent for chronic
tests. (Manual, Chapter 7B, page 7-16; Biomonitoring module, Chapter 5, page 5-2)
2. List three results that would be questionable for acute testing (Manual, Chapter 8C, page 8-12).
b.
c.
3. The is the calculated percentage of effluent at which 50 percent of the test organisms die during the
test period. (Manual, Chapter 8C, page 8-12; Biomonitoring module, Chapter 2, page 2-7)
4. The highest tested concentration at which test organisms' responses are not statistically different from the control
organisms' responses is called the . (Manual, Chapter 8C, page 8-13; Biomonitoring module,
Chapter 2, page 2-8)
5. The ChV, which stands for , is calculated by . (Biomonitoring module, Chapter
2, page 2-8)
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UNIT 8 TOXICITY
UNIT 8 EXAM 1 HOUR
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time limit listed above.
3. Verify the answers with your instructor.
4. Correct any errors and clarify questions or problems before proceeding to Unit 9.
Exam Questions
1. List four objectives of a biomonitoring inspection.
b.
c.
d.
2. Describe how effluent samples used for WET testing purposes should be stored.
3. List four procedures the inspector should evaluate when reviewing a laboratory's test organism handling and
maintenance procedures.
b.
c.
d.
4. Explain where receiving water should be obtained for use as dilution water.
5. Explain when it is necessary to conduct an abbreviated, preliminary range-finding or screening test.
6. Explain the basis of a definitive toxicity test.
7. List the three types of toxicity tests based on how the test organisms are exposed to test solutions.
NPDES INSPECTION MANUAL SEPTEMBER 1995
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TOXICITY UNIT 8
a.
b.
c.
8. Explain how temperature control is normally achieved during toxicity testing.
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PRETREATMENT UNIT 9
UNIT NINE
PRETREATMENT
EPA has developed two types of onsite reviews to evaluate POTW and IU compliance with pretreatment
program requirements. These include pretreatment program audits and Pretreatment Compliance Inspections (PCIs).
Pretreatment audits evaluate all aspects of a POTW s pretreatment program, and therefore, are more comprehensive
than PCIs [which principally evaluate compliance monitoring (sampling and inspection) and enforcement activities].
Unit 9 corresponds to Chapter 9 of the Manual and EPA's 1990 NPDES Compliance Inspector Training Overview
module. More information on pretreatment program requirements may be obtained from the guidance manuals listed
in Chapter 9 of the Manual. Topics covered in this unit include:
• Review of the General Pretreatment Regulations
• PCIs and audits.
EXERCISE 9-1 REVIEW OF THE GENERAL 2 HOURS
PRETREATMENT REGULATIONS
Understanding the basic concepts of the General Pretreatment Regulations and the requirements and
responsibilities of EPA, States, POTWs, and industries is essential to the inspector's evaluation of
pretreatment program implementation and enforcement. These issues are covered in this exercise.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 9A of the Manual, 40 CFR Part 403 (the General Pretreatment Regulations), and Chapter
6 of the NPDES Compliance Inspector Training Overview module.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List the three specific objectives of the General Pretreatment Regulations. (Manual, Chapter 9A, page 9-1;
40 CFR Part 403; Overview module, Chapter 6, page 6-1)
a.
b.
c.
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UNIT 9 PRETREATMENT
2. List the specific areas in which the Control Authority has responsibility to implement the pretreatment program.
(Manual, Chapter 9A, pages 9-3 through 9-4)
3. Discuss the public-participation requirements that a Control Authority must meet to adequately implement its
pretreatment program. [Manual, Chapter 9A, page 9-5; 40 CFR 403.5(c)(3) and 40 CFR 403.8(f)(2)(vii)]
4. List three types of discharge standards or requirements with which industrial dischargers must comply.
(Manual, Chapter 9A, page 9-6; 40 CFR Part 403)
a.
b.
c.
5. List five types of reports required of IDs by 40 CFR 403.12. (Manual, Chapter 9A, page 9-10; 40 CFR
403.12)
a.
b.
c.
d.
e.
6. Describe briefly when the combined wastestream formula is needed and the purpose of its use. [Manual,
Chapter 9A, page 9-6; 40 CFR 403.6(e)]
7. Explain the basis of categorical pretreatment standards and their point of application. (Manual, Chapter 9A,
page 9-6; 40 CFR 403.6)
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STUDENT'S GUIDE 9-2
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PRETREATMENT UNIT 9
8. Explain who (EPA, the State, or the Control Authority) is responsible for establishing and periodically re-
evaluating local limits to prevent interference, pass through, and/or sludge contamination. [Manual, Chapter
9A, page 9-4; 40 CFR 403.5(c)]
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UNIT 9 PRETREATMENT
EXERCISE 9-2 PCfe AND AUDITS 30 MINUTES
PCIs and audits evaluate POTW and IU efforts to meet Federal, State, and local POTW program
requirements. NPDES inspectors are asked to conduct PCIs in conjunction with visits to POTWs for other
NPDES inspections. This exercise and the corresponding text provide inspectors with an introduction to, and
an overview of, PCIs and audits.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 9B of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material hi this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Discuss the differences between a PCI and an audit. (Manual, Chapter 9B, page 9-19; Overview module,
Chapter 6, pages 6-2 and 6-9)
2. Describe three previsit preparation responsibilities. (Manual, Chapter 9B, page 9-16)
a.
b.
c.
3. Describe seven onsite responsibilities. (Manual, Chapter 9B, page 9-16)
a.
b.
c.
d.
e.
f.
NPDES INSPECTION MANUAL SEPTEMBER 1995
STUDENT'S GUIDE 9-4
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PRETREATMENT UNIT 9
tJNTF 9 EXAM 45 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time limit above.
3. Verify all the answers with your instructor.
4. Correct any errors and clarify questions or problems before proceeding to Unit 10.
Exam Questions
1. Identify the part and section of the CFR which sets forth State and POTW regulations and requirements of the
National Pretreatment Program.
2. List the three objectives of the General Pretreatment Regulations.
a.
b.
c.
3. Define the terms "interference" and "pass through."
a. Interference
b. Pass through
4. List five of the specific prohibitions in 40 CFR 403.5(b).
a.
b.
c.
d.
e.
SEPTEMBER 1995 NPDES INSPECTION MANUAL
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UNIT 9 PRETREATMENT
5. A POTW with an approved pretreatment program is located in a State that has not been approved by EPA to
implement a State pretreatment program. List the Control Authority and the Approval Authority.
a.
b.
6. Metal finishing is a Federally regulated category with specific discharge standards for lUs.
TRUE I—I FALSE I I (Check one. If the statement is false, make necessary changes to correct it.)
7. A Control Authority has developed local limits that are less stringent than Federal categorical standards
promulgated for the electrical and electronic components industry. An industry which is subject to those
Federal standards discharges process wastewaters directly to the sewer without combining with other
wastestreams. The Control Authority may apply the less stringent local limits to the lU's discharge.
TRUE LJ FALSE LJ (Check one. If the statement is false, make necessary changes to correct it.)
8. The PCI is a comprehensive review of all facets of a POTW's pretreatment program.
TRUE LJ FALSE LJ (Check one. If the statement is false, make necessary changes to correct it.)
NPDES INSPECTION MANUAL SEPTEMBER 1995
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SEWAGE SLUDGE UNIT 10
UNIT TEN
SEWAGE SLUDGE
EPA has promulgated technical standards for the use or disposal of sewage sludge. Consequently, sludge use
and disposal requirements are being included in NPDES permits when they are reissued. Evaluation of sludge
management activities and compliance with sewage sludge regulations is intended to be incorporated into the existing
inspection structure. Therefore, inspectors need to be familiar with the sewage sludge regulations and how to
evaluate a facility's compliance with those regulations. Unit 10 corresponds to Chapter 10 of the Manual. Topics
covered in this unit include:
« Review of the sewage sludge regulations
• Sludge inspection procedures.
EXERCISE 10-1 REVIEW OF THE SEWAGE 45 MINUTES
SLUDGE REGULATIONS
Understanding the sewage sludge regulations and their applicability to generators and preparers of sewage
sludge is necessary so that inspectors can adequately determine compliance. This exercise provides an
overview of the sewage sludge regulations.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 10A of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List the three sewage sludge use and disposal practices for which technical standards have been promulgated
under 40 CFR Part 503. (Manual, Chapter 10A, page 10-1)
a.
b.
c.
2. List the five types of requirements under 40 CFR Part 503. (Manual, Chapter 10A, page 10-2)
a.
b.
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UNIT 10 SEWAGE SLUDGE
c.
d.
e.
3. Most sewage sludge records for land application and surface disposal are required to be maintained for a
minimum of . (Manual, Chapter 10A, pages 10-4 and 10-5)
4. Pathogen reduction treatment processes used to achieve Class A sludge are referred to as
and treatment processes used to achieve Class B sludge are referred to as
. (Manual, Chapter 10A, page 10-4)
5. List the three classes of facilities that are required to report at least once per year under 40 CFR Part 503.
(Manual, Chapter 10A, page 10-5)
a.
b.
c.
6. Surface disposal sites that are equipped with a liner and leachate collection system are not required to meet any
pollutant concentration limits. (Manual, Chapter 10A, page 10-5)
TRUE EH FALSE ED (Check one. If the statement is false, make necessary changes to correct it.)
7. List the 40 CFR Part 503 three types of monitoring requirements for sewage sludge incinerators. (Manual,
Chapter 10A, page 10-6)
a.
b.
c.
NPDES INSPECTION MANUAL SEPTEMBER 1995
STUDENT'S GUIDE 10-2
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SEWAGE SLUDGE UNIT 10
EXERCISE 10-2 SLUDGE INSPECTION PROCEDURES I HOUR
30 MINUTES
Inspectors should incorporate evaluation of sewage sludge use and disposal practices into existing
inspections as much as possible. This exercise provides inspectors with an introduction to how to evaluate
whether a facility is in compliance with the sewage sludge regulations, including sample collection and
analysis.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 10B and Appendices I and J of the Manual and watch the video Sampling Sewage
Sludge.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List the six steps an inspector should do while preparing for an inspection. (Manual, Chapter 10B, pages 10-10
through 10-11)
a.
b.
c.
d.
e.
2. List five items that should be included in a sewage sludge sampling plan. (Video)
a.
b.
c.
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UNIT 10 SEWAGE SLUDGE
d.
e.
3. In general terms, describe where sewage sludge samples should be collected. (Manual, Chapter 10B, pages
10-12 and 10-17, video)
4. In general terms, describe how composite samples are collected for metals analysis. (Video)
5. Describe how sewage sludge samples should be preserved in the field. (Manual, Chapter 10B, pages 10-12 and
10-17, video)
6. Describe where in the Code of Federal Regulations approved analytical methods for sewage sludge analyses
are listed. (Manual, Chapter 10B, page 10-13)
7. List the three elements related to sewage sludge laboratory analysis that are evaluated during a PAI. (Manual,
Chapter 10B, pages 10-17 through 10-18)
a.
b.
c.
8. Part 503 pollutant standards are expressed on a weight basis. (Manual, Chapter 10B, page 10-18)
NPDES INSPECTION MANUAL SEPTEMBER 1995
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SEWAGE SLUDGE UNIT 10
9. Describe the sewage sludge parameter that must be known to convert pollutant concentrations from a wet to
a dry weight basis. (Manual, Chapter 10B, page 10-19)
10. Describe the appropriate location and method for sampling composted sludge. (Manual, Chapter 10B, page
10-23, Video)
11. List the appropriate records that may be kept to demonstrate compliance with Class A, Alternative Al,
pathogen reduction. (Manual Chapter 10B, page 10-24)
a.
b.
c.
12. List the appropriate records that may be kept to demonstrate compliance with vector attraction reduction Option
1. (Manual, Chapter 10B, page 10-27)
a.
b.
SEPTEMBER 1995 NPDES INSPECTION MANUAL
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UNIT 10 SEWAGE SLUDGE
UNIT 10 EXAM 30 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time listed above.
3. Verily the answers with your instructor.
4. Correct any errors and clarity questions or problems before proceeding to Unit 11.
Exam Questions
1. List the three sewage sludge use and disposal practices for which technical standards have been promulgated
under 40 CFR Part 503.
a.
b.
c.
2. All sewage sludge that is land applied must meet pollutant limits.
3. Part 503 regulations contain management practices for and of sludge use and disposal
activities.
4. Vector attraction reduction requirements are intended to
5. Required minimum self-monitoring frequencies for land application or surface disposal of sewage sludge are
based on .
6. In general, sewage sludge records must be maintained for a minimum of three years.
TRUE I I FALSE I I (Check one. If the statement is false, make necessary changes to correct it.)
7. Samples for pathogen analyses should be collected directly into sampling containers.
8. Describe how sewage sludge samples should be preserved in the field.
9. Sample containers for liquid sewage sludge should be completely rilled for all pollutant analyses.
TRUE LJ FALSE LJ (Check one. If the statement is false, make necessary changes to correct it.)
NPDES INSPECTION MANUAL SEPTEMBER 1995
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SEWAGE SLUDGE UNIT 10
10. Approved analytical methods for sewage sludge analyses are contained in 40 CFR Part 136.
TRUE LJ FALSE LJ (Check one. If the statement is false, make necessary changes to correct it.)
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STORM WATER UNIT 11
UNIT ELEVEN
STORM WATER
Under the storm water regulations, certain point source storm water dischargers must apply for a storm water
discharge permit. As a result, NPDES inspectors may be inspecting facilities which have NPDES permits that
include storm water requirements and conditions. To be able to assess a facility's compliance with the storm water
regulations and applicable permit requirements, inspectors need to be familiar with the regulations. Unit 11
corresponds to Chapter 11 of the Manual. Topics covered in this unit include:
• Storm water regulations
* Storm water permits
• Sampling and inspection considerations.
EXERCISE 11-1 STORM WATER REGULATIONS 45 MINUTES
Understanding the storm water regulations and their applicability to facilities being inspected is necessary so
that inspectors can adequately determine compliance. This exercise provides an introduction to the storm
water regulations and permit application procedures.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 11A of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List the three general types of dischargers that are regulated under the storm water regulations. (Manual,
Chapter 11 A, page 11-7)
a.
b.
c.
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UNIT 11 STORM WATER
2. List the three types of permit applications for storm water discharges associated with industrial activities.
(Manual, Chapter 11 A, page 11-5)
a.
b.
c.
3. Describe what a light industrial facility that determines that there is no exposure to storm water should do.
(Manual, Chapter 11 A, page 11-3)
4. Industrial storm water discharges include immediate access roads and rail lines that are used by a facility's
carriers of raw materials, products, waste materials, or by-products. (Manual, Chapter 11A, page 11-3).
TRUE CD FALSE CD (Check one. If the statement is false, make necessary changes to correct it.)
5. Industrial facilities that want to be covered under a general permit must file a . (Manual,
Chapter 11 A, page 11-6)
6. Under Section 402(p)(4) of the CWA, permits must require compliance no later than after the permit
issuance date. (Manual, Chapter 11 A, page 11-8)
NPDES INSPECTION MANUAL SEPTEMBER 1995
STUDENT'S GUIDE 11-2
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STORM WATER UNIT 11
EXERCISE 11-2 STORM WATER PERMITS 45 MINUTES
To be able to determine a facility's compliance with applicable storm water regulations, inspectors need to
be familiar with conditions normally included in storm water discharge permits. These issues are covered
in this exercise.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 11B and Appendix K of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List five requirements included in EPA's baseline general permits. (Manual, Chapter 11B, page 11-15)
a.
b.
c.
d.
e.
2. Pollution Prevention Plans for industrial activities must contain a description of and a
description of to prevent or minimize pollution of storm water. (Manual, Chapter
1 IB, page 11-15)
3. List three types of pollutant measures or controls that may be included in a Pollution Prevention Plan for
industrial activities. (Manual, Chapter 11B, page 11-16)
a.
b.
c.
4. The EPA baseline general permit includes additional requirements for facilities that have discharges associated
with industrial activity and are subject to
. (Manual, Chapter 11B, page 11-17)
5. List the three types of controls that must be included in Pollution Prevention Plans for construction activity.
(Manual, Chapter 11B, page 11-19)
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UNIT 11 STORM WATER
a.
b.
c.
6. List the four types of pollutant sources that must addressed in storm water management programs for municipal
separate storm sewer systems. (Manual, Chapter 11B, page 11-21)
a.
b.
c.
d.
NPDES INSPECTION MANUAL SEPTEMBER 1995
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STORM WATER UNIT 11
EXERCISE 11-3 SAMPLING AND INSPECTION 1 HOUR
CONSIDERATIONS 15 MINUTES
Inspectors should be familiar with sources of storm water pollutants and procedures for collecting samples
to characterize these pollutants. In addition, inspectors should be familiar with storm water flow
measurement considerations and inspecting for illicit connections. These issues are covered in this exercise.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 11C and Appendices L through Q of the Manual.
3, Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List the six activities associated with industrial activities that have been identified as major potential sources
of storm water pollutants. (Manual, Chapter 11C, page 11-27)
a,
b.
c.
d.
e.
f.
2. List three conditions that make storm water sampling difficult and may require adjustment to sampling plans.
(Manual, Chapter 11C, page 11-29)
a.
b.
c.
3. The storm water regulations specify that the storm event to be sampled must be at least after
the previously measurable storm event (greater than 0.1 inches). (Manual, Chapter 11C, page 11-29)
4. EPA's general storm water permit requires that monitoring records be maintained for a minimum of
. (Manual, Chapter 11C, page 11-30)
5. List four items the inspector should assess to verify that outfalls receive storm water discharges from
substantially identical outfalls. (Manual, Chapter 11C, page 11-30)
a.
b.
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UNIT 11 STORM WATER
c.
d.
6. List the four most common methods of measuring storm water flow. (Manual, Chapter 11C, page 11-31)
a.
b.
c.
d.
7. List and describe the two types of illicit connections to storm sewer systems. (Manual, Chapter 11C, page
11-31)
a.
b.
8. List the two steps an inspector can follow to evaluate facilities for illicit connections. (Manual, Chapter 11C,
page 11-32)
a.
b.
9. List four conditions that may indicate that an illicit connection exists. (Manual, Chapter 11C, page 11-33)
a.
b.
c.
d.
NPDES INSPECTION MANUAL SEPTEMBER 1995
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STORM WATER UNIT 11
UNIT 11 EXAM 30 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time listed above.
3. Verify the answers with your instructor.
4. Correct any errors and clarify questions or problems before proceeding to Unit 12.
1. List the three general types of dischargers that are regulated under the storm water regulations.
a.
b.
c.
2. List three types of pollutant measures or controls that may be included in a Pollution Prevention Plan for
industrial activities.
a.
b.
c.
3. List the four types of pollutant sources that must addressed in storm water management programs for municipal
separate storm sewer systems.
a.
b.
c.
d.
4. List six activities associated with industrial activities that have been identified as major potential sources of
storm water pollutants.
a.
b.
c.
d.
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UNIT 11 STORM WATER
e.
f.
5. The storm water regulations allow permittees to sample and report monitoring data on only one of two or more
substantially identical outfalls.
TRUE I I FALSE I I (Check one. If the statement is false, make necessary changes to correct it.)
6. The runoff coefficient method of estimating storm water flow is very accurate.
TRUE LJ FALSE LJ (Check one. If the statement is false, make necessary changes to correct it.)
7. and are two tests that can be key indicators of non-storm water discharges.
NPDES INSPECTION MANUAL SEPTEMBER 1995
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COMBINED SEWER OVERFLOWS UNIT 12
UNIT TWELVE
COMBINED SEWER OVERFLOWS
Many municipalities have combined sanitary and storm sewer systems that result in Combined Sewer Overflows
(CSOs) during wet weather events. Since these CSOs are considered point sources of pollution, they are subject
to the NPDES permit program. NPDES inspectors may have to determine a facility's compliance with EPA's 1994
CSO control policy and CSO conditions contained in NPDES permits. Unit 12 corresponds to Chapter 12 of the
Manual. Topics covered include:
• The CSO control policy
• CSO inspection procedures.
EXERCISE 12-1 THE CSO CONTROL POLICY 30 MINUTES
Inspectors should be familiar with EPA's CSO control policy so that a facility's compliance with that policy
can be determined. This exercise provides an overview of the EPA's CSO control policy.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 12A of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. CSOs are not subject to secondary treatment requirements. (Manual, Chapter 12A, page 12-1)
TRUE LJ FALSE LJ (Check one. If the statement is false, make necessary changes to correct it.)
2. List the four steps that the CSO control policy encourages permittees to take. (Manual, Chapter 12A, page 12-1
through 12-2)
a.
b.
c.
d.
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UNIT 12 COMBINED SEWER OVERFLOWS
3. List the nine minimum CSO controls. (Manual, Chapter 12A, page 12-3)
a.
b.
c.
d.
e.
f.
g-
h.
i.
4. List the nine elements of LTCPs. (Manual, Chapter 12A, page 12-3)
a.
b.
c.
d.
e.
f.
g-
h.
NPDES INSPECTION MANUAL SEPTEMBER 1995
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COMBINED SEWER OVERFLOWS UNIT 12
EXERCISE 12-2 CSO INSPECTION PROCEDURES 45 MINUTES
Inspectors should evaluate a facility's compliance with its NPDES CSO permit conditions and the CSO
control policy. This exercise covers basic CSO inspection procedures.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 12B of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List the two documents in which requirements for CSO control can be found. (Manual, Chapter 12B, page
12-5)
a.
b.
2. After permit issuance, permittees are usually given 2 years to submit a report documenting implementation of
the nine minimum controls. (Manual, Chapter 12B, page 12-5)
TRUE LJ FALSE LJ (Check one. If the statement is false, make necessary changes to correct it.)
3. List five areas for which the compliance inspector should obtain information to determine compliance.
(Manual, Chapter 12B, page 12-5)
a.
b.
c.
d.
e.
4. List the four steps inspectors may take when determining compliance with CSO controls. (Manual, Chapter
12B, pages 12-5 through 12-8)
a.
b.
c.
d.
5. List four types of CSO records a facility may maintain. (Manual, Chapter 12B, page 12-7)
SEPTEMBER 1995 NPDES INSPECTION MANUAL
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UNIT 12 COMBINED SEWER OVERFLOWS
a.
b.
c.
d.
6. A schedule submitted by a permittee in its LTCP is an enforceable schedule. (Manual, Chapter 12B, page
12-7)
TRUE LJ FALSE ED (Check one. If the statement is false, make necessary changes to correct it.)
7. List five examples of records or documents a permittee may maintain to demonstrate proper operation and
maintenance of the combined sewer system. (Manual, Chapter 12B, page 12-9)
a.
b.
c.
d.
e.
8. Describe what the inspector should do if any dry weather CSO discharges are observed. (Manual, Chapter 12B,
page 12-8)
NPDES INSPECTION MANUAL SEPTEMBER 1995
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COMBINED SEWER OVERFLOWS UNIT 12
UNIT 12 EXAM 15 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time listed above.
3. Verify the answers with your instructor.
4. Correct any errors and clarify questions or problems before proceeding to Unit 13.
1. List the four steps that the CSO control policy encourages permittees to take.
a.
b.
c.
d.
2. List the nine minimum CSO controls.
a.
b.
c.
d.
e.
f.
g-
h.
i.
3. List the two documents in which requirements for CSO control can be found.
a.
b.
4. Inspections of CSO outfalls are routinely conducted as part of NPDES inspections.
TRUE ED FALSE CD (Check one. If the statement is false, make necessary changes to correct it.)
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OVERVIEW OF POLLUTION PREVENTION UNIT 13
UNIT THIRTEEN
POLLUTION PREVENTION
The goal of pollution prevention is to achieve the reduction of pollution by the elimination or reduction of
waste. Although inspectors may be limited in incorporating pollution prevention assessments into NPDES
inspections, inspectors can identify pollution prevention options that would improve compliance. Therefore,
inspectors should be familiar with the basics in identifying pollution prevention opportunities. Topics covered in
the exercises in this unit (which corresponds to Chapter 13 of the Manual) include:
* Overview of pollution prevention
• Pollution prevention for industrial facilities
• Pollution prevention for municipal wastewater treatment plants.
EXERCISE 13-1 OVERVIEW OF POLLUTION PREVENTION 30 MMUTES
To be able to identify pollution prevention opportunities, inspectors should be familiar with the goals and
benefits of pollution prevention and the waste management hierarchy. These issues are covered in this
exercise.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter ISA of the Manual.
3, Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Pollution prevention is intended to minimize or eliminate pollutants released without shifting pollutants from
one media to another. (Manual, Chapter 13A, page 13-1)
TRUE LJ FALSE LJ (Check one. If the statement is false, make necessary changes to correct it.)
2. List four ways by which a facility can implement pollution prevention. (Manual, Chapter 13A, page 13-1)
a.
b.
c.
d.
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UNIT 13 OVERVIEW OF POLLUTION PREVENTION
3. List the four levels of the waste management hierarchy. (Manual, Chapter 13A, pages 13-2 through 13-3)
a.
b.
c.
d.
4. Describe source reduction. (Manual, Chapter 13A, page 13-2)
5. Evaporating spent electroplating baths is an example of pollution prevention. (Manual, Chapter 13A, page 13-3)
TRUE LJ FALSE LJ (Check one. If the statement is false, make necessary changes to correct it.)
6. List three direct benefits of pollution prevention. (Manual, Chapter 13A, pages 13-4 and 13-6)
a.
b.
c.
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OVERVIEW OF POLLUTION PREVENTION UNIT 13
EXERCISE 13-2 POLLUTION PREVENTION FOR 45 MINUTES
INDUSTRIAL FACILITIES
During inspections of industrial facilities, inspectors can identify pollution prevention opportunities through
evaluation of facility layout, equipment and processes, and waste generation, handling, and disposal. This
exercise covers the basics of identifying pollution prevention opportunities at industrial facilities.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 13B and Appendix R of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List the four phases of pollution prevention opportunity assessments. (Manual, Chapter 13B, page 13-7)
a.
b.
c.
d.
2. To better enable the inspector to identify pollution prevention opportunities, detailed information should be
collected to develop a for each process step. (Manual, Chapter 13B, page 13-7)
3. List the six areas or activities the inspector should focus on during the facility site visit. (Manual, Chapter
13B, page 13-10)
a.
b.
c.
d.
e.
f.
4. List the four types of wastestreams that should be evaluated during a facility site visit. (Manual, Chapter 13B,
page 13-10)
a.
b.
c.
d.
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UNIT 13 OVERVIEW OF POLLUTION PREVENTION
5. List two examples of how a facility could achieve the goal of pollution prevention through the use of fewer
resources. (Manual, Chapter 13B, page 13-11)
a.
b.
6. List the five pieces of information the inspector should gather information on for each identified wastestream.
(Manual, Chapter 13B, page 13-10)
a.
b.
c.
d.
e.
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OVERVIEW OF POLLUTION PREVENTION UNIT 13
EXERCISE 13-3 POLLUTION PREVENTION FOR 30 MINUTES
MUNICIPAL WASTEWATER TREATMENT PLANTS
The Municipal Water Pollution Prevention (MWPP) program promotes the application of pollution
prevention concepts to POTWs. During inspections of POTWs, inspectors can assess the POTW's current
pollution prevention practices and identify pollution prevention opportunities. These issues are covered in
this exercise,
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 13C of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. List four benefits for implementing pollution prevention at POTWs. (Manual, Chapter 13C, page 13-15)
a.
b.
c.
d.
2. List three benefits of reducing sewer system infiltration/inflow. (Manual, Chapter 13C, page 13-16)
a.
b.
c.
3. Implementing pollution prevention through the pretreatment program is one of the best ways to control
pollutants at their source. (Manual, Chapter 13C, page 13-16)
TRUE LJ FALSE O (Check one. If the statement is false, make necessary changes to correct it.)
4. List five areas on which POTWs could focus pollution prevention practices. (Manual, Chapter 13C, page 13-
15)
a.
b.
c.
d.
e.
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UNIT 13 OVERVIEW OF POLLUTION PREVENTION
UNIT 13 EXAM 15 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time listed above.
3. Verify the answers with your instructor.
4. Correct any errors and clarify questions or problems before proceeding to Unit 14.
1. List four ways by which a facility can implement pollution prevention.
a.
b.
c.
d.
2. List the four levels of the waste management hierarchy.
a.
b.
c.
d.
3. Inspectors generally will be able to conduct full pollution prevention opportunity assessments as part of NPDES
compliance inspections.
TRUE CU FALSE L~H (Check one. If the statement is false, make necessary changes to correct it.)
4. List the six areas or activities the inspector should focus on during the facility site visit.
a.
b.
c.
d.
e.
f.
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OVERVIEW OF POLLUTION PREVENTION UNIT 13
5. List four benefits for implementing pollution prevention at POTWs.
a.
b.
c.
d.
6. The is one of the best ways to control pollutants discharged to a POTW at their source.
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MULTI-MEDIA CONCERNS UNIT 14
UNIT FOURTEEN
MULTI-MEDIA CONCERNS
NPDES inspectors may find it necessary to evaluate a facility's compliance with applicable environmental
regulations in media other than wastewater. Therefore, inspectors may need to be familiar with other environmental
programs such as RCRA, CERCLA, and air. Topics covered in this unit (which corresponds to Chapter 14 of the
Manual) include:
* Introduction and overview
• Multi-media concerns and the screening program
• Multi-media inspections.
EXERCISE 144 INTRODUCTION AND OVERVIEW 15 MINUTES
Inspectors may be called upon to perform multi-media inspections of varying depth and complexity. This
exercise provides an introduction to the various levels of multi-media inspections that may be conducted.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapters 14A and 14B of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Describe the difference between Category A and Category B inspections. (Manual, Chapter 14B, page 14-3)
2. Category A inspections are the most complex multi-media inspections. (Manual, Chapter 14B, page 14-3)
TRUE LJ FALSE LJ (Check one. If the statement is false, make necessary changes to correct it.)
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UNIT 14 MULTI-MEDIA CONCERNS
3. List the five advantages to conducting multi-media inspections as opposed to program-specific inspections.
(Manual, Chapter 14B, page 14-4)
a.
b.
c.
d.
e.
NPDES INSPECTION MANUAL SEPTEMBER 1995
STUDENT'S GUIDE 14-2
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MULTI-MEDIA CONCERNS UNIT 14
EXERCISE 14-2 MULTI-MEDIA CONCERNS AND 1 HOUR
THE SCREENING PROCESS 30 MINUTES
Inspectors that participate in multi-media inspections should have a basic understanding of other
environmental program areas. This exercise provides a brief overview other program areas.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 14C and Appendices S and T of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. RCRA regulates the of hazardous waste. (Manual, Chapter 14C, page 14-5)
2. The control of hazardous waste discharged directly to surface waters is deferred to the CWA under the direct
discharge exclusion. (Manual, Chapter 14C, page 14-5)
TRUE EH FALSE CH (Check one. If the statement is false, make necessary changes to correct it.)
3. List the four fates of hazardous wastes that are discharged to wastewater treatment plants. (Manual, Chapter
14C, page 14-5)
a.
b.
c.
d.
4. POTWs that receive hazardous wastes by track, rail, or dedicated pipeline are subject to RCRA
requirements. (Manual, Chapter 14C, page 14-5)
5. RCRA and the regulate the cleanup of
hazardous waste sites. (Manual, Chapter 14C, page 14-6)
6. Municipal sewage sludge that is co-incinerated with other wastes is regulated by the .
(Manual, Chapter 14C, page 14-6)
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UNIT 14 MULTI-MEDIA CONCERNS
EXERCISE 14-3 MULTI-MEDIA INSPECTIONS 30 MINUTES
Multi-media inspections are generally performed by an inspection team. This exercise provides an
overview of team responsibilities and required skills.
1. Read through the study checklist. Test your background knowledge by responding to as many items as
possible.
2. Read Chapter 14D of the Manual.
3. Respond to each item on the study checklist. Correct any errors and expand any incomplete responses
made in Step 1. Discuss any questions or problems with your instructor. Do not proceed until you
have mastered the material in this exercise.
Study Checklist At the end of this exercise, you should be able to:
1. Describe the two steps in the basic strategy for performing multi-media inspections. (Manual, Chapter 14D,
page 14-9)
a.
b.
2. Each multi-media inspection team member should have expertise in each program area being evaluated.
(Manual, Chapter 14D, page 14-10)
TRUE LJ FALSE LJ (Check one. If the statement is false, make necessary changes to correct it.)
3. The has overall responsibility for conducting a multi-media inspection. (Manual, Chapter 14D,
page 14-10)
4. List five skills or qualifications that each multi-media team member should possess. (Manual, Chapter 14D,
page 14-10)
a.
b.
c.
d.
e.
NPDES INSPECTION MANUAL SEPTEMBER 1995
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MULTI-MEDIA CONCERNS UNIT 14
UNIT 14 EXAM 15 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time listed above.
3. Verify the answers with your instructor.
4. Correct any errors and clarify questions or problems before proceeding to the final exam.
1. Inspections that focus on one specific program area but also screen for possible noncompliance in other
program areas are Category investigations.
2. Category C investigations are conducted by a team of investigators and focus on two or more targeted program
areas.
TRUE CH FALSE d (Check one. If the statement is false, make necessary changes to correct it.)
3. RCRA regulates the of hazardous waste.
4. List the four fates of hazardous wastes that are discharged to wastewater treatment plants.
a.
b.
c.
d.
5. The has overall responsibility for conducting a multi-media inspection.
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FINAL EXAM
APPENDIX A
FINAL EXAM
AUGUST 1995 NPDES INSPECTION MANUAL
STUDENT'S GUIDE
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FINAL EXAM
FINAL EXAM
FINAL EXAM 2 HOURS
30 MINUTES
Instructions
1. Complete this exam without referring to any text or notes.
2. Do not exceed the time limit noted above.
Exam Questions
1. Identify the sections of the CWA listed below by number.
a. Effluent Limitations
b. Information and Guidelines
c. Inspections, Monitoring, and Entry
d. NPDES
2. List the five steps involved with preinspection planning.
a.
b.
c.
d.
3. Indicate the legal requirement an inspector must meet on arrival at a facility.
4. Describe the purpose of the inspector's field notebook.
5. Routine record-keeping and reporting evaluations are conducted at all permittee facilities. Explain why an in-depth
investigation would be warranted and give one example.
6. List the two objectives of a facility site review.
a.
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FINAL EXAM
b.
7. List four areas or conditions of a plant which are evaluated during a facility site review.
a.
b.
c.
d.
8. List four specific objectives of sampling a permittee's effluent.
a.
b.
c.
d.
9. List the two types of sampling techniques and when each type is appropriate.
a.
b.
10. Describe the kinds of information that should be contained in a permittee's self-monitoring records (i.e., the
laboratory data management system).
11. Describe a chain-of-custody form and explain its primary objective.
12. List the five reasons why accurate flow measurement is important.
a.
b.
c.
d.
e.
13. Usually, the inspector is encouraged to use the facility's system if it is accurate. Describe the conditions under
which the inspector would use a portable flow sensor and recorder.
14. Describe the standard elements of a complete, continuous flow measurement system.
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FINAL EXAM
15. List four objectives of a biomonitoring inspection.
a.
b.
c.
d.
16. Define QA and QC.
a. OA
b. PC
17. Describe the NPDES DMR QA program.
18. List four features or services that quality-conscious laboratories should have on hand.
a.
b.
c.
d.
19. Indicate the regulatory topic that is addressed in 40 CFR Part 403.
20. Describe the purpose of the National Pretreatment Program.
21. List three types of standards imposed on lUs under a pretreatment program.
a.
b.
c.
22. A toxicity test in which the effluent and dilution water are continuously replenished in test chambers is called a
test.
23. A toxicity test estimates the concentration at which a predetermined toxic response occurs.
24. Describe where effluent samples for biomonitoring should be taken .
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FINAL EXAM
25. Adding dilution water to the water that organisms were raised in prior to a test is called
26. The types of sampling the inspector may undertake at the facility are determined by the terms and conditions of
the permit.
TRUE O or FALSE \J (Check one. If the statement is false, make necessary changes to correct it.)
27. EPA inspectors may visit a facility which has not been issued a permit.
TRUE vJ or FALSE vJ (Check one. If the statement is false, make necessary changes to correct it.)
28. List the three sewage sludge use and disposal practices for which technical standards have been promulgated
under 40 CFR Part 503.
a.
b.
c.
29. All sewage sludge that is land applied must meet pollutant limits.
30. In general, sewage sludge records must be maintained for a minimum of three years.
TRUE vJ or FALSE vJ (Check one. If the statement is false, make necessary changes to correct it.)
31. Describe how sewage sludge samples should be preserved in the field.
32. Sample containers for liquid sewage sludge should be completely filled for all pollutant analyses.
TRUE O or FALSE O (Check one. If the statement is false, make necessary changes to correct it.)
33. Approved analytical methods for sewage sludge analyses are contained in 40 CFR Part 136.
TRUE O or FALSE O (Check one. If the statement is false, make necessary changes to correct it.)
34. List the three general types of dischargers that are regulated under the storm water regulations.
a.
b.
c.
35. List the four types of pollutant sources that must addressed in storm water management programs for municipal
separate storm sewer systems.
a.
b.
c.
d.
36. List six activities associated with industrial activities that have been identified as major potential sources of storm
water pollutants.
a.
b.
c.
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FINAL EXAM
d.
e.
f.
37. and are two tests that can be key indicators of non-storm water discharges.
38. List the four steps that the CSO control policy encourages permittees to take.
a.
b.
c.
d.
39. List the nine minimum CSO controls.
a.
b.
c.
d.
e.
f.
g-
h.
i.
40. List the two documents in which requirements for CSO control can be found.
a.
b.
41. List four ways by which a facility can implement pollution prevention.
a.
b.
c.
d.
42. List the four levels of the waste management hierarchy.
a.
b.
c.
d.
43. Category A inspections are the most complex multi-media inspections.
TRUE vJ or FALSE vJ (Check one. If the statement is false, make necessary changes to correct it.)
44. Describe the two steps in the basic strategy for performing multi-media inspections.
a.
b.
45. RCRA regulates the of hazardous waste.
AUGUST 1995 NPDES INSPECTION MANUAL
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FINAL EXAM
46. List the four fates of hazardous wastes that are discharged to wastewater treatment plants.
a.
b.
c.
d.
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REFERENCES
APPENDIX B
REFERENCES
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REFERENCES
REFERENCES
APHA, AWWA, and WEF. Standard Methods for the Examination of Water and Waste-water (Use the most current,
accepted edition).
U.S. EnvironmentalProtectionAgency. 1973. Maintenance Management Sy stems forMunicipal Waste-water Facilities.
EPA-430/9-74-004.
U.S. EnvironmentalProtectionAgency. 1978. Field Manual for Performance Evaluation and Trouble-Shooting at
Municipal Wastewater Treatment Facilities. MO No. 16, EPA-430/9-78-001.
U.S. EnvironmentalProtectionAgency. 1979. Methodsfor Chemical Analysis of Water and Wastes. EPA-600/4-79-020.
U.S. Environmental Protection Agency. 1982. Handbook for Sampling and Sample Preservation of Water and
Wastewater. EPA-600/4-82-029.
U.S. Environmental Protection Agency. 1990. NPDES Compliance Monitoring Inspector Training Overview module.
U.S. EnvironmentalProtectionAgency. 1990. NPDES Compliance Monitoring InspectorTrainingLegallssuesmodule.
U.S. Environmental Protection Agency. 1990. NPDES Compliance Monitoring Inspector Training Biomonitoring
module.
U.S. Environmental Protection Agency. 1990. NPDES Compliance Monitoring Inspector Training Sampling
Procedures module.
U.S. EnvironmentalProtectionAgency. 1990. NPDES Compliance Monitoring InspectorTrainingLaboratory Analysis
module.
U.S. EnvironmentalProtectionAgency. 1992. "Inspecting a Par shall Flume" video.
U.S. EnvironmentalProtectionAgency. 1993. "Conducting a Records Inspection" video.
U.S. Environmental Protection Agency. 1993. "Sampling Waste-water at a Waste-water Treatment Facility"video.
U.S. EnvironmentalProtectionAgency. 1994. "Conducting a Performance Audit Inspection at a Facility Performing
Toxicity Testing" video.
U.S. Environmental Protection Agency. September 1994. NPDES Compliance Inspection Manual.
Federal Water Pollution Control Act, 33 U.S.C. 1251 et seq. as amended by the Water Quality Act of 1987, P.L. 100-4,
February 4, 1987.
• Code of Federal Regulations. Title 40, Part 122, "EPA Administered Permit Programs: The National Pollutant
Discharge Elimination System."
• Code of Federal Regulations. Title 40, Part 136, "Guidelines Establishing Test Procedures for the Analysis of
Pollutants."
• Code of Federal Regulations. Title 40, Part 403," General Pretreatment Regulations forNew and Existing Sources."
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