1. Florida Industrial Pretreatment Association Workshop April 25, 2008 Dan Parnell JEA Industrial Pretreatment

2. Inspection Overview Things you need to think about Preparation Conducting the annual inspection Spill plans What ifs….

3. Types of Inspection Annual Spot or Demand Pre-permit Sampling

4. Annual Inspections – Things to Think About Why? Meet FDEP & EPA requirements Verify compliance w/ permit Identify changes at facility Maintain relationship w/ IU community When? Annually

5. Annual Inspections – More Things to Think About What? Find and trace all established waste streams (process) and potential waste streams (aka spills). How? Trace all raw materials coming in, processing through, and product (waste too!) leaving the facility.

6. Annual Inspections – Even More Things to Think About To schedule or not to schedule Unscheduled – no prior notice given to IU More representative of daily operations Suggested if IU is having compliance issues Surprise factor - IU may not have best personnel on site that day

7. Annual Inspections – Ready for Multitudes of Things to Think About? To schedule or not to schedule Scheduled How much advance notice? More likely to have best suited IU representative present, leads to quality inspection Establishes better rapport w/ industries

8. Annual Inspections – Its Friday Afternoon, Your Probably Tired of Thinking About Things Frequency Requirement: once every 12 months When is increased frequency appropriate? Compliance history Type of processes High hydraulic and pollutant loadings Seasonal production rates

9. Annual Inspection - Phases Planning & Prep Inspection Spill Control Plan Write Report

10. Annual Inspection Planning & Prep

11. Annual Inspection – The Inspection Phases Pre-inspection meeting Document Review Physical inspection Post inspection meeting

12. Annual Inspection – Pre-inspection Meeting Getting in Introduce yourself & purpose Show credentials Consent must be given to conduct inspection Sign in Log waivers or releases

13. Annual Inspection – Pre-inspection Meeting Discuss: Reason for inspection Paperwork to review Areas to visit Safety - PPE

14. Annual Inspection – Doc Review Docs to review: Waste manifest Lab documents Lab data QA/QC COC Flow & pH logs Pretreatment system operational logs Documents required due to categorical regulations

15. Annual Inspection – Physical Inspection Process Areas: Tips: control pace keep ‘em talking explore (but ask!) look for overhead pipes Where to visit: water de-mineralization mix tanks production lines clean in place systems loading docks

16. Annual Inspection – Physical Inspection Drains… Process Areas: Trays… and Autofills! The only good drain is a sealed drain.

17. Annual Inspection – Physical Inspection Process Areas: Categorical considerations Organic Chemical Manufacturing Process Sample Point Noncontact Cooling water Vehicle Maintenance

18. Annual Inspection – Physical Inspection Boiler Rooms & Cooling Towers

19. Annual Inspection – Physical Inspection Chemical Storage Areas Berm, Baby Berm! The Good The Ugly! The Bad

20. Annual Inspection – Physical Inspection Pretreatment Removal technologies

21. Annual Inspection – Physical Inspection Pretreatment Solids Handling

22. Annual Inspection – Physical Inspection Sample Point & Flow Measurement

23. Annual Inspection – Post Inspection Review findings w/ representative Discuss deficiencies/corrective actions Use opportunity To discuss any anticipated changes in IP program Answer (or refer) questions IU may have concerning utility

24. Annual Inspection – Spill Plan Review each SIUs need for a spill plan every 2 years

25. Annual Inspection – Report Review notes Write report Timeliness Document everything No blanks Send follow up letter: bad & good

26. What If… consent for inspection not given? IU delays entry? IU won’t let you take pictures? you feel safety is jeopardized during inspection? consent is given & later withdrawn? escort must leave and tells you to finish on your own? IU claims inspection results are confidential? you find a garden hose discharging to their sample point?

27. Inspection Conclusions Quality inspections are accomplished through preparation, understanding what to look for, and knowing where to find it..