How To Survive a Regulatory Plant Inspection

How To Survive a Regulatory Plant Inspection
During a plant inspection walkthrough, answer all questions asked without over explaining. Take the inspector on the most direct route through all the treatment trains and avoid problem areas.

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Whether it’s the U.S. EPA or the Department of Water Quality, an agency can strike fear in municipalities when it’s time for plant inspections. It is not that plants have something to hide or are discharging substandard water, but no one likes to be under the microscope — especially under the microscope of a regulatory agency with the power to impose fines. 

As a former chief operator and plant superintendent, I know the anxiety of escorting an inspector throughout your plant. 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 team can make to satisfy regulatory agencies. 

Know your permit inside and out

NPDES permits regulate facilities that discharge to water bodies or treat wastewater. Each treatment works must obtain and implement these standards that must be meet performance-based and narrative requirements. 

Performance-based standards are derived from the technology of the treatment process the plant utilizes. 

Narrative standards are the compliance levels that cannot be exceeded by a plant (i.e. water-quality standards). 

Inspectors use the NPDES permit as a guide to whether or not your plant is in compliance in the following areas: 

  • Compliance Evaluation Inspection (CEI)
  • Compliance Sampling Inspection (CSI)
  • Performance Audit Inspection (PAI)
  • Fifth Year Inspection (FYI) 

David Smicherko, a Florida Department of Environmental Protection compliance supervisor, explained each of these inspections in a 2003 presentation

  • CEI — This is a general evaluation for the compliance schedules, laboratory, sampling procedures, records, reports, flow measurements, effluent, disposal, residual management, and operations and maintenance.
  • CSI — The agency samples the facility’s effluent to determine if guidelines are met.
  • PAI — This is an in-depth evaluation and audit of the facility and laboratory including sampling methods, sampling points and paperwork (i.e. chain of custody sheets, labeling, initials and certifications).
  • FYI — The agency does a priority pollutants and toxicity screening. 

Knowing your permit requirements directs the utility to meet goals and specific criteria to pass an inspection. When a plant’s performance exceeds permit requirements reveals to the inspector that the facility is a top-notch facility.

Time for inspection

Announced inspections

Some inspectors give a complimentary heads-up phone call to let you know they will be on-site within a certain time period. That gives the utility time to: 

  • Review plant performance
  • Clean the plant grounds and high travel areas
  • Verify that all documents are in order
    • Current permit and modifications
    • Facility record drawings
    • Operator licenses
    • Calibration and maintenance records
  • Check and repair maintenance issues in the facility that relate to critical plant components 

A trained inspector will check for access control, the overall condition of the process tanks, grounds and odors. Well-run plants should have no trouble meeting inspector regulations. 

Pay attention to detail when cleaning the plant and checking for deficiencies. Ask these questions:

  • Why is that hose running along the clarifier catwalk?
  • Does this hose bib have a backflow prevention device?
  • Is the plant permit and O&M manual readily available to staff members?
  • Are all the sample points marked?
  • What does the headworks and sludge building look like?
  • Where are the areas that produce odors and why?
  • Have all of the flowmeters, instrumentation, and other meters been calibrated in compliance with the permit? 

Unannounced inspections

A compliance inspector reserves the right to inspect a treatment plant at any time without previous approval or appointment. Therefore, a well-managed plant should be prepared for an impromptu inspection with minimal disruption to the facility. 

Using a detailed plant checklist is the best way to be a step ahead. The list should include checks for each stage of the process based on the PAI or past compliance inspection. Each shift should conduct the inspection at least once, but twice a shift is preferable.

The walkthrough

The face-to-face interaction between the inspector and plant staff members 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 over explaining. 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?

Here are some quick tips to ensure the best inspection:

  • Take notes during the walkthrough
  • Take pictures wherever the inspector takes pictures (from the same angle)
  • Make conversation to lighten the mood
  • Find out what you can about the inspector, such as past inspection histories, time on the job, background in process control and treatment plant
  • Don’t let the grumpiest operator do the inspection

Post inspection

At the end of the inspection, make sure you understand exactly what deficiencies were discovered and the necessary 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 inspection as a topic to meet with upper management and staff members 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.

About the Author

Sheldon Primus is a Class A licensed wastewater operator with more than 18 years of industry experience. He is a Certified Occupational Safety Specialist, authorized OSHA outreach instructor, and holds master’s degrees in public administration and environmental policies. He has held positions as a laboratory operator, chief operator, plant superintendent, safety and compliance officer, and industrial pretreatment coordinator.

Primus is CEO of Utility Compliance Inc. based in Port St. Lucie, Fla., which helps utilities in industrial pretreatment and risk management program compliance, water and wastewater CEU training, as well as occupational safety program development and OSHA outreach training for general industry and construction. He is also an online adjunct instructor for the Environmental Science Department at Florida Gateway College.

He can be reached at sheldon@utilitycompliance.net or 888/398-0120. 



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