--Facility Inspection--Industrial Pretreatment

The District’s facility inspection program is an important tool in measuring the overall environmental performance of our Pretreatment Program. Every industrial user receives a full inspection on a regular frequency. Each significant industrial user receives a full inspection annually as do users who are subject to high strength surcharge. Other users receive inspections at lesser frequencies, which vary with the type of activity conducted by the industry. Additional inspections are made at any time it is found necessary to address specific concerns or to investigate possible violations. 

Emphasis in training our inspectors focuses not only on uncovering violations or improper practices, but also on assisting facility contacts in understanding regulatory requirements, making them aware of pollution prevention techniques and the importance of timely and accurate reporting for assistance in identifying and solving problems. While we will drop the enforcement hammer when appropriate, we have found that emphasizing guidance and assistance first is an effective way to build trust, minimize program problems and reduce user violations.

Most inspections are scheduled shortly in advance of the actual inspection. However, if we have any reason to believe that a user may take unusual steps to “prepare” for an announced inspection, we will make unannounced inspections as per the authority contained in our sewer use ordinance.

Proper preparation by the inspector is a key element in ensuring an effective inspection. Our inspectors review past inspection reports, sampling data, environmental permits, slug control and other waste management plans and other correspondence. Regulations known or thought to be applicable to the facility are also reviewed. The inspector familiarizes himself or herself with the facility layout, locations of on-site sewers, sampling locations and nearby District sewers prior to the actual visit.

A full inspection includes the following steps: opening interview with the facility contact, physical tour of the entire facility to observe processes, checking of sampling points and downstream sewers and exit interview with the facility contact. An inspection report form, consisting of a list of specific questions, most of which are broken down into subparts, is used by the inspector. The questions are designed to uncover and address any conceivable activity that might impact the quantity or character of wastewater discharges from the facility. An example is a question concerning possible venting of air pollution control devices or exhaust fans to roof areas from which vented pollutants might be washed off into sewers or surface drainage. Another example addresses the disposal of storm water from storage tank containment facilities. Some questions appear to repeat previously asked information. This is an intentional effort to address certain topics from different perspectives. This tactic often elicits additional information or forces the contact to re-evaluate an earlier response. We have found this to be particularly effective in ensuring complete information is obtained.

During the initial interview the inspector goes through every item on the inspection form with the facility contact, emphasizing any areas of specific concern identified during the preparation step. Direct observation and further questioning, during the facility tour, often clarifies or corrects items discussed during the initial interview. The facility tour encompasses the entire site, including warehousing and other non-process areas. Our inspectors are trained and instructed to poke into every nook and cranny of a facility. With the exception of avoiding obvious safety hazards, the facility contact is not allowed to “lead” the inspector.  We feel this procedure is essential to verify the accuracy of previously provided information and to ensure that all activities that can impact wastewater discharges are addressed. This policy has proven effective in identifying unlisted drains, improperly stored materials and other questionable conditions that might otherwise have gone undetected or unreported.

It is not unusual for this process to result in “opening the eyes” of the facility contact, particularly if the contact is relatively new, into areas of concern they were not aware of at their own facility. Sampling locations are also checked to make sure they are accessible and to ensure they actually capture the intended wastewater flows. Doubts are resolved through dye testing during the inspection or on a return visit. Downstream sewers are inspected for evidence of unusual discharge/damage. Following the facility tour, the contact is advised of any actions they need to take to address items of concern. Follow-up contacts are made by phone or mail to address specific questions or to provide additional guidance. These thorough and detailed facility inspections allow the District to monitor the industrial compliance and effectiveness of the Pretreatment Program and are only made possible by “above and beyond” training of inspectors and pre-visit preparation.