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Thursday, May 28, 2020
9:00 am - 10:30 am
CWEA Environmental Compliance Inspector - Grade 1 Certification Training Webinar
CWEA Contact Hours: 1.8 towards Environmental Compliance Inspector certification
Introducer: Eric Van Cleave, Southern California Regional Sales Manager, SmartCover Eric Van Cleave is the Southern California Regional Sales Manager with SmartCover Systems. He has a degree in Industrial and Manufacturing Engineering from the University of Missouri and started working for SmartCover Systems in June 2017. He previously worked in Environmental Construction and has been in Engineering Sales for the past 8 years. He is also the TCP Chair for the CWEA San Diego Section.
Moderator: TBD
Speaker: Shannon Simmers, Regulatory Compliance Officer, City of Redlands Shannon Simmers, Regulatory Compliance Officer for the City of Redlands, CA is responsible for the Pretreatment Program and other regulatory requirements for the City’s WWTP, collections system and stormwater requirements to name a few. She has worked in the Environmental Compliance Field since 2014. Prior to that she worked in the production industry where she held positions as a Final Inspector, Quality Control Technician and a Quality Assurance Lab Technician. She holds the following certifications: an ECI Grade 2, QISP, a Wastewater Operator Grade 2, a Water Treatment Operator Grade 1, and a Distribution Operator Grade 1. She has an Associates Science degree in Water Supply Technology. She is a P3S Executive Committee Past Chair and the TCP Training Liaison. She is involved in several projects with CWEA and other organizations such as the TCP Train the Trainer program and the CSUS PFI Update Subcommittee. She is also a Subject Matter Expert for the ECI exam and was involved with the recent ECI exam re-validation and revisions to the ECI Study guides.
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Skills Based TrainingENVIRONMENTAL COMPLIANCE INSPECTOR
ECI Grade 1 Job KnowledgeToday we will cover these topic areas:
KSA 107
KSA 119
KSA 115
ECI Grade 1 Exam Blueprint & Suggested References
AGENDA
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ECI Grade 1: KSA 107
KSA 107 Description
Clean, inspect, and maintain sampling equipment, meters and related test apparatus. (4%)
● Calibrate sampling equipment and gas detectors.
● Understand proper use of sampling equipment, field blanks, and the importance of Quality Assurance when sampling.
● Describe proper preservation methods according to 40 CFR 136.
KSA 319
Image Caption
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Blue Print and Other Reference Material
Pretreatment Facility Inspection: A Field Study Training Program, 3rd Edition, 3rd Printing 2010. Chapter 4, Appendix II‐ Pretreatment Arithmetic
40 CFR 403
Industrial Waste Treatment, 2nd
Edition, Volume 1
Gas Monitor
KSA 107
Confined Space Atmospheric Hazards
•IDLH: Immediately Dangerous to Life or HealthImmediate danger to life or health
•UEL: Upper explosive LimitMaximum concentration of a flammable gas or vapor that will support combustion when ignition source is present
•LEL: Lower Explosive LimitMinimum concentration of a flammable gas or vapor that will support combustion when ignition source is present
•TLV: Threshold Limit ValueAverage concentration of a gas or other substance that is safe for normal operation with out injury in an average work week
KSA 107
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Atmospheric Conditions
Three atmospheric conditions can exist
•Too lean to support combustion
•Mixture just right, explosion occurs
•Mixture too rich to support combustion
PFI 5.2
Photo Curtesy of
https://www.google.com/url?sa=i&source=images&cd=&cad=rja&uact=8&ved=2ahUKEwjgzJiSlaLlAhXxFjQIHb7zDP0Qjhx6BAgBEAI&url=https%3A%2F%2Fwww.exveritas.com%2Fintroduction‐to‐expolsive‐atmospheres%2F&psig=AOvVaw1S0f0Q9w7YN70zl1MlDUCa&ust=1571362890920271
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0%‐100% of LEL is how testing equipment is set.
The alarm set point is 10% of the LEL.
0% ‐ 100%
Gas MonitorAlarm Set Points
Gas Range Alarm Set Point
O2: 0-25% Below 19.5% & over 22.5%
Explosive: 0-100% 10% LEL
H2S: 0-50 ppm 10 ppm
CO: 0-100 ppm 35 ppm
KSA 107
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USEOFGAS DETECTOR
• THE USE OF A GAS DETECTOR
DOES NOT REPLACE THE NEED
FOR A RESPONSIBLE PERSON TO
MAKE DECISIONS BASED ON
HAZARD ASSESSMENT.
• DEVICE SHOULD BE CALIBRATED
ACCORDING TO MANUFACTURE
RECOMMENDATIONS
• CALIBRATION DATA SHOULD BE
KEPT IN A LOG BOOK.PHOTO COURTESY OF: HTTP://HOLYSHITTHATSINTERESTING.BLOGSPOT.COM/2013/07/HOLY‐SHIT‐GUADALAJARA‐EXPLOSIONS.HTML
KSA 107KSA 107 9
Grab vs. Composite SampleGRAB
•Represents only one point in time.
• Useful when enforcing discharge standards or for operator process control.
•A sample taken with in a 15 minute time frame.
•Can be taken quickly before conditions change.
•Not always enforceable.
•Some methods required grab samples due to the volatility of the constituent or other concerns.
When would you take a grab sample?
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Grab vs. Composite SampleCOMPOSITE
•A number of grab samples that are taken at specific intervals and volume.
•Represent the discharge over a specific time period. Usually 24 hours.
•Better for characterizing wastewater than a grab sample.
•Flow weighted or time weighted
•Combined or discrete.
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Importance of QA/QCEPA Handbook
•Analytical data provides qualitative and quantitative date for use in decision making.
•To be valuable, data must be accurately describe the characteristic and concentrations of the waste stream being sampled.
•Approximations or incorrect results are worse than no results at all.
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Photo courtesy of:https://www.nature.com/news/how‐quality‐control‐could‐save‐your‐science‐1.19223
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Importance of QA/QCEPA Handbook
•Since this data is often times used to determine control measures and compliance at a facility the precision and accuracy of the data is relied upon greatly.
•Taking appropriate QA/QC measures will ensure that sampling procedures, sampling methods, and sample analysis, and sample results will be enforceable in the case where legal action is necessary.
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Photo courtesy of:https://www.nature.com/news/how‐quality‐control‐could‐save‐your‐science‐1.19223
QA/QC Terms
Accuracy:
Refers to the degree of difference between observed values and known or actual values in the analysis of wastewater. (EPA)
Determined by Degree of difference from known value (actual) value.
Precision:
A measure of agreement among repeated measurements of the same property under identical, or substantially similar, conditions; expressed generally in terms of the standard deviation. (EPA)
Estimated by comparing the measurements.
PFI Chapter 6.60
EPA Industrial User Inspection and Sampling Manual for POTWs
https://www.google.com/url?sa=i&source=images&cd=&cad=rja&uact=8&ved=0ahUKEwjjkrHPmJLnAhXdB50JHdD1ClEQMwi7ASgwMDA&url=https%3A%2F%2Fmedium.com%2F%40kay.huang%2Fdata‐science‐machine‐learning‐neural‐network‐artificial‐intelligence‐these‐buzzword‐got‐us‐all‐361c4464aab5&psig=AOvVaw0qC9qtJGhYo8bGIX7kWFTX&ust=1579610182121567&ictx=3&uact=3
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QA/QC Terms
Quality Assurance:
An integrated system of management activities involving planning, implementation, documentation, assessment, reporting, and quality improvement to ensure that any samples taken and any analysis performed on those samples is of the type and quality needed and expected. (EPA)
Program functions set up to assure the quality of measurements. (PFI)
Quality Control:
The overall process that measure the attributes and performance of sampling and sample analysis against defined standards to verify that they meet the stated requirements established by the Quality Assurance Program. (EPA)
Process and specific activates for the purpose of carrying out procedure in QA program. (PFI)
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QA/QC Terms
Qualitative: Non‐numerical data
Quantitative: Numeric data
PFI Chapter 6.60
EPA Industrial User Inspection and Sampling Manual for POTWs
https://www.google.com/url?sa=i&source=images&cd=&cad=rja&uact=8&ved=0ahUKEwjo0ofjmpLnAhVbVc0KHcQaD98QMwhPKAEwAQ&url=http%3A%2F%2Fintellspot.com%2Fqualitative‐vs‐quantitative‐data%2F&psig=AOvVaw1ZQZZtLIjwCsRpDLd_hLhM&ust=1579610760289915&ictx=3&uact=3
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QA/QC Program Primary Functions
TWO PRIMARY FUNCTIONS
To monitor and evaluate continues reliability (precision and accuracy).
1. How will the quality of the data received be judged for acceptability.
2. How to control the quality of data to meet program requirements.
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CATEGORIES OF PRIMARY FUNCTIONS
1. Field Procedures
2. Laboratory Procedures
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QA/QC Procedures for SAMPLING
QA Procedures
‐Assigned analytical method, handling procedures and detections limits to pollutants that will be analyzed.
‐Reasoning for choosing the information listed above.
‐Percent of QC checks and the type of checks to be performed.
‐Establish calibration procedures.
‐Establish a performance evaluation process.
QC Procedures
‐Preparing calibration and PM procedure for equipment.
‐Maintain Documentation Record of specifications, calibrations, expiration data and maintenance schedule.
‐Develop and implement SOP’s for all aspects of the sampling program.
‐Perform QC checks during actual sampling events in accordance with QA program to determine the performance of sampling techniques.
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QC Checks
Duplicate Samples(field): During a sampling event to different sets of sampling equipment is used or two different grab sample are collected at the same time and in the same location.
*This is used to verify precision of sampling equipment and techniques.
Equipment Blank: During a sampling event, an aliquot of contaminate free water, which is opened in the field, is ran through the sampling equipment and then analyzed.
*This is used to determine the sampling device cleanliness.
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https://www.dreamstime.com/stock‐illustration‐ecology‐control‐environmental‐pollution‐flat‐style‐colorful‐vector‐cartoon‐illustration‐chemist‐takes‐samples‐sewage‐image87062739
QC Checks
Field Blank: During a sampling event, an aliquot of contaminate free water, which is kept sealed, is brought into the field and transported back to the laboratory with the other sample containers.
*This is used to determine if there is sample contamination occurring during the event.
Preservation Blank: An aliquot of contaminate free water to which a known concentration of preservative is added and then analyzed .
*This is used to determine effectiveness of preservative.
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https://www.dreamstime.com/stock‐illustration‐ecology‐control‐environmental‐pollution‐flat‐style‐colorful‐vector‐cartoon‐illustration‐chemist‐takes‐samples‐sewage‐image87062739
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PFI 6- Sampling Procedures for Wastewater - Table 6.1
•Oil & Grease Glass; 4/6 deg.; pH<2 HCl or H2SO4; 28 d
•Cyanide P or G; 4/6 deg.; pH 12 NOH; 14 d
•BOD P or G; 4/6 deg.; 48 hrs
•Phenols g only; 4/6 deg.; pH<2 H2SO4; 28 d
KSA 107
PFI 6- Sampling Procedures for Wastewater - Table 6.1
•pH P or G; analyze within 15 mins
•Chromium P or G; 4/6 deg.; 48 hrs
•Metals* P or G; 6 months
•Mercury P or G; pH <2 HNO2
KSA 107
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ECI Grade 1: KSA 119
KSA Description
Perform sampling of sanitary sewer overflows (SSOs) where appropriate. Recall the different categories of sanitary sewer overflows, the required notifications, and reporting.
• Identify what sampling procedures and precautions that must be taken when dealing with SSO.
Image Caption
KSA 119
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Blue Print and Other Reference Material
SWRCB General Order WQO2006 003 and 2013 Monitoring and Reporting Order
SWRCB Enrollee’s Guide to the SSO Database
SSO into waterway
KSA 119
SSO ConcernsSSOs often cause significant environmental and public health problems. They can pollute the surface waters; endanger aquatic life; interfere with recreational uses and industry resources; and contaminate drinking water supplies.
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Actions and Precautions
During an active SSO the goal is to:
1) Control or limit the volume of untreated or partially treated wastewater discharged,
2) terminate the discharge, and
3) recover as much of the wastewater discharged as possible for proper disposal, including any wash down water.
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Actions and Precautions
Implement all remedial actions possible by:
1) Intercept and reroute untreated or partially treated wastewater flows around the line failure;
2) Vacuum truck recovery of sanitary sewer overflows and wash down water;
3) Cleanup of debris at the overflow site;
4) Adequate sampling to determine the nature and impact of the release;
5) Adequate public notification to protect the public from exposure to the SSO; and
6) System modifications to prevent another SSO at the same location.
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SSO CategoriesThere are three categories of spills with specific definitions designed to direct the responsible agency in how to properly preform notification and reporting of the spill. It is based on the amount and destination of the spill.
KSA 119
Categories
Discharges of untreated or partially treated wastewater of any volume resulting from an enrollee’s (POTW’s) sanitary sewer system failure or flow condition that:
Reach surface water and/or reach a drainage channel tributary to a surface water; or
Reach a municipal separate storm sewer system and are not fully captured and returned to the sanitary sewer system or not otherwise captured and disposed of properly. Any volume of wastewater not recovered from the municipal separate storm sewer system is considered to have reached surface water unless the storm drain system discharges to a dedicated storm water or ground water infiltration basin (e.g., infiltration pit, percolation pond).
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Private Lateral Sewer Discharge
Discharges of untreated or partially treated wastewater resulting from blockages or other problems within a privately owned sewer lateral connected to the enrollee’s (POTW’S) sanitary sewer system or from other private sewer assets.
PLSDs that the enrollee (POTW) becomes aware of may be voluntarily reported to the SSO Database.
KSA 119
Reporting
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SSO Sampling
•Sampling, or water quality monitoring, should be conducted within 48 hours after initial SSO notification for Category 1 SSOs in which 50,000 gallons or greater are spilled to surface waters. Upload Water quality results into CIWQS.
•Sampling should be adequate to determine the nature and impact of the release.
•Sampling should not be performed during unsafe conditions and/or when heavy rain flow will cause sampling results to be unrepresentative.
•Public Notification should be proved based on the level of human and environmental hazards. This may constitute signage only or a combination of signage; direct public notification, news and social media outlets, neighboring agencies, and downstream receiving waters.
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ECI Grade 1: KSA 115
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KSA DescriptionAssist in maintaining program compliance with federal, state and local requirements through the issuing of permits and by guiding non‐compliant users back to compliance. Explain the inspection frequency for all Significant Industrial Users.
• Understand terms and definitions relating to indirect and permitted dischargers.
• Describe the federal regulations regarding pollutants and permitted dischargers, and control dischargers.
• Identify the effectiveness of wastewater permits.
KSA 115
Blue Print and Other Reference Material
Pretreatment Facility Inspection: A Field Study Training Program, 3rd Edition, 3rd Printing
2010. Chapter 3, Appendix III‐Pretreatment Words
KSA 115
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Polling Question #6
Does your agency have an approved pretreatment program?
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A) YesB) NoC) I do not know
Objectives of General Pretreatment Regulations.By establishing the responsibilities of government and industry to implement National Pretreatment Standards this regulation fulfills three objectives:
(a) To prevent the introduction of pollutants into POTWs which will interfere with the operation of a POTW, including interference with its use or disposal of municipal sludge;
(b) To prevent the introduction of pollutants into POTWs which will pass through the treatment works or otherwise be incompatible with such works; and
(c) To improve opportunities to recycle and reclaim municipal and industrial wastewaters and sludges.
(40 CFR 403.2)
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Significant Industrial User (SIU)
Definition:
•All industrial users subject to Categorical Pretreatment Standards under 40 CFR 403.6 and 40 CFR chapter I, subchapter N; and
•Any other Industrial User that discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary, noncontact cooling and boiler blowdown wastewater);
•or contributes a process wastestream that makes up 5 percent or more of the average dry‐weather hydraulic or organic (BOD, TSS, and such) capacity of the POTW treatment plant;
•or is designated as such because there is reasonable potential for adversely affecting the POTW’s operation or for violating any pretreatment standard or requirement
KSA 115
Significant Industrial User (SIU)
Inspection Frequency:
POTWs are required to inspect all SIUs at least once a year. Additional inspections might be necessary depending on issues such as the variability of an SIU’s effluent, the effect of the SIU’s discharge on the POTW, and the facility’s compliance history. Inspection considerations hinge on the type of inspection performed .
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KSA 115
Source of PollutantPoint Source:
•Pollutant comes from a specific identifiable source such as POTW’s and industrial dischargers. Easier to control at source with permits, treatments and use of BMP’s.
•Non‐Point Source:
•Comes from a wide variety of sources that can run‐off the surface during rain events or illegal discharges. Harder to control and effects are widespread. May need general permit with control measures to share responsibility.
POINT SOURCE NON‐POINT SOURCE
Industrial and urban run‐off
https://www.google.com/search?q=point+source+versus+non‐point+source+pollution&rlz=1C1KMZB_enUS750US750&source=lnms&tbm=isch&sa=X&ved=2ahUKEwjWwIuWtJLnAhVMLKwKHTajAYMQ_AUoAXoECBAQAw&biw=1920&bih=1089#
Types of DischargersIndirect Discharger:
•Non‐Point discharges from an industry into a POTW.
•EPA’s National Pretreatment Program requires these dischargers to treat or control pollutants in their wastewater before discharge to POTWs.
•These discharges are regulated under the 40 CFR 430.3
Direct Discharger:
•Point source that discharges directly into waters of the US.
•Subject to EPA’ National Pollutant Discharge Elimination System (NPDES) program regulations.
•Permitted directly through the EPA or State Water Board.
• https://www.google.com/imgres?imgurl=x‐raw‐image%3A%2F%2F%2F1e9a738aeab5a33370c138a66c3d268835d68ff336ef0f779b5af41453cc526e&imgrefurl=https%3A%2F%2Fcdn.ymaws.com%2Fwww.azwater.org%2Fresource%2Fgroup%2Fff292f94‐3eca‐421f‐bb63‐48f3210be537%2Fevents%2F2016‐07‐28%2FPretreatment‐POTW_Police.pdf&docid=u_gCjY0m9_HCoM&tbnid=M6O16opzmh6XJM%3A&vet=10ahUKEwiAjIW4rJLnAhVCaM0KHRXYDioQMwhLKAUwBQ..i&w=1066&h=646&bih=1089&biw=1920&q=indirect%20discharger%20vs%20direct%20discharger&ved=0ahUKEwiAjIW4rJLnAhVCaM0KHRXYDioQMwhLKAUwBQ&iact=mrc&uact=8
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Key Terms Existing Source: Dischargers that existed at the time of the promulgation of a pretreatment standard.
•New Source: Any source of discharge, new building or construction that is in existence after the promulgation of a pretreatment standard. Must be independent or substantially different from any existing source in the same location.
•PSES: Pretreatment Standards for Existing Source
•PSNS: Pretreatment Standards for New Source
•NSPS: New Source Performance Standards
•BPT: Best Practicable Control Technology
•BCT: Best Conventional Pollutant Control Technology
•BAT: Best Available Technology Economically Achievable
Levels of Control
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PSES vs PSNSPretreatment Standards
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PSES Metal Finishing Standards
Pollutant or pollutant property
Maximum for any 1 day
Milligrams per liter (mg/l)
Cadmium (T) 0.69 0.26
Chromium (T) 2.77 1.71
Copper (T) 3.38 2.07
Lead (T) 0.69 0.43
Nickel (T) 3.98 2.38
Silver (T) 0.43 0.24
Zinc (T) 2.61 1.48
Cyanide (T) 1.20 0.65
TTO 2.13
PSNS Metal Finishing Standards
Pollutant or pollutant property
Maximum for any 1 day
Monthly average shall not exceed
Milligrams per liter (mg/l)
Cadmium (T) 0.11 0.07
Chromium (T) 2.77 1.71
Copper (T) 3.38 2.07
Lead (T) 0.69 0.43
Nickel (T) 3.98 2.38
Silver (T) 0.43 0.24
Zinc (T) 2.61 1.48
Cyanide (T) 1.20 0.65
TTO 2.13
Benefits of a Permit•To ensure compliance with pretreatment standards.
•Clearly identify dischargers responsibilities.
•Greater understanding of dischargers process.
•Accommodate federal, sate and local requirements.
•Protect the POTW, WWTP process, Public, Staff, and the environment.
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TCP Candidate Handbook, KSA Gap Analysis & ECI Blueprints
QUESTIONS?TRAINER: [email protected]
(909) 557‐6298
CWEA: [email protected]
(510) 382‐7800
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