Whether the name is the State Department of Environmental Protection Agency or Department of Water Quality, or some other name, the agency can strike fear in municipalities when they inspect the plant. It is not that most plants have something to hide or are discharging inferior water, but no one likes to be under the microscope. Let alone under the microscope of a regulatory agency with the power to fine the utility.
As a former chief operator and plant superintendent, I know the anxiety it brings when you have to escort an inspector throughout the process. However, there are a few tips that I learned along the way to keep these inspections cordial and even welcomed. There is no magic formula for pleasing regulators, but there are steps that the utility management can make to satisfy the regulatory agencies.
Know Your Permit Inside And Out
Each treatment works falls under the Clean Water Act of 1971, that created the National Pollution Discharge and Eliminations System (NPDES) permits to regulate facilities that discharge to water bodies or treat wastewater. Each plant has standard that must be meet such as Performance-based standards or Narrative standards.
Performance-based standards are technically derived from the technology of the treatment that the plant utilizes.
Narrative standards are simply a statement directed to the plant to state a level of compliance that cannot be exceeded.
Inspectors use your NPDES permit as the guide to whether or not you plant is in compliance in the following areas:
A Florida Department of Environmental Protection (FDEP) compliance agent explains each of these Inspections as:
Knowing your permit gives the utility direction as goals and specific criteria it must hit in order to pass an inspection. The plant performance that does better than the permit requirement will announce to the inspector that the facility is top notch plant.
Some inspectors give a complimentary call to let you know their intention to inspect within a certain time period. That gives the utility time to:
A trained inspector will look at a facility to check for access control, the overall condition of the process tanks, grounds, and odors. Well run plants will look the part and give an air of competency to the regulatory inspector. Pay attention to detail when cleaning the plant and checking for deficiencies. Ask yourself questions like:
Each compliance inspector reserves the right to inspect a treatment plant at any time without prior approval or appointment. Therefore, the well managed plant will be prepared for an impromptu inspection with minimal disruption to the plant. The best way to be a step ahead is using a detailed plant checklist. This list must include check for each stage of the process and based on the PAI or past compliance inspection. Each shift should conduct the inspection at least once, but twice a shift is preferable.
This face to face interaction is paramount to the success of the inspection and future inspections. A strong handshake and genuine smile makes a great first impression. Then follow up that greeting with knowledge of the permit, calibration records, and other compliance paperwork.
During the walkthrough, answer all questions asked without trying to over explain anything. Take the inspector on the most direct route through all the treatment trains and avoid problem areas. Why create more questions than necessary by taking the easy path through the area that isn’t inspection ready?
Author Sheldon Primus (left) provides consultation for inspections.
At the end of the inspection, make sure you understand exactly what deficiencies were discovered and steps for abatement. Ask the inspector for the specific timeframe that the utility has to respond in writing to the noted issues. In addition, make sure to exchange contact information with direct lines for effective communication.
After the inspector leaves, use the inspections as a topic to meet with upper management and the staff at different times to review the process and findings. The plant superintendent can then make adjustments to the operator checklist, maintenance practices, and laboratory procedures. Every inspection can be a valuable tool for the utility and a catalyst to plant awards.