What To Expect At Your DEQ Compliance Inspection to Expect DEQ Compliance... · What To Expect At Your DEQ Compliance Inspection ... Identify any questions you have for the inspector

What To Expect At Your

DEQ Compliance

Inspection

Ryan Blazic

DEQ – Water Bureau

Gaylord Field Office

989-705-3420

Disclaimer

Your inspector and you,

partners with the same goal

DEQ Inspector’s Role

Regulatory Considerations

Part 31 of the NREPA (Water Resources

Protection)

NPDES Permits (Surface Water)

Groundwater Discharge Permits (Groundwater)

Your DEQ Inspector

Wide range of education/experience

Typically educated in environmental, biology, chemistry,

engineering, etc.

Wastewater training classroom/OJT

Many different assignments (spill response, multiple

programs, committee work)

Inspections

Three Basic Types

Reconnaissance Inspections

Compliance Evaluation

Inspections

Sampling Inspections

Checklists

Announced vs.

Unannounced

Inspection Frequency

Inspection Elements

Pre-Inspection

Opening and Closing Conference

Records Review

Facility Walkthrough

Sampling

Interview

Post-Inspection

Pre-Inspection

DEQ Preparation

WWTP recommendations to facilitate the

inspection:

Organize records to be able to locate information easily

Review past inspection information to make sure all

deficiencies have been corrected from previous

inspections

Identify any safety or special considerations

Identify any questions you have for the inspector

And ……

Read and understand the permit

Read and understand the permit

Read and understand the permit

Read and understand the permit

Read and understand the permit

Read and understand the permit

Read and understand the permit

Read and understand the permit

Read and understand the permit

Opening Conference

Exchange cards and contact information

Explanation of what will be evaluated

Answer any questions

Time expected to take

Right of entry

And….

Records Review

DMR & Bench Sheet Comparison

Accuracy

Missing Information

Laboratory Records (Calibration Records,

Temperature Logs, etc.)

Laboratory Procedures

Commercial Lab Records

QA/QC Program

O & M Records

Records Recommendations

Ensure you write legibly

Group programs (O&M, QA/QC,

Laboratory Procedures, etc.)

Ensure information is corrected

appropriately (line out and initial)

Ensure your recordkeeping is consistent

Facility Walkthrough

Sampling Equipment

(Temperature, Condition,

Settings)

Chemical Feed Systems &

Secondary Containment

General Safety

Treatment System Condition

and Operation

General Housekeeping

Laboratory Equipment

Flow Measurement

Lift Stations (Condition,

Maintenance)

Facility Walkthrough

Recommendations

Interact during the walkthrough as much as

possible

Point out improvements

Point out things that you are working on

upgrading

Point out modifications

Explain the wastewater treatment process

Provide a treatment system diagram

Sampling

Typically part of a Compliance

Sampling Inspection

Chris and Cindy

Unannounced

Spits

Composites

District staff can also sample

Send results w/ inspection &

findings

Sampling Recommendations

Ensure your composite sampler is collecting

enough volume to split samples

Ask questions

Interview

Facility History

Plant Specifications & Operation

Staffing, Training, and Operator

Certification

Emergency Procedures

Complaints Received, Spills, SSOs, ect.

Plant Updates and Changes

Permit Information

Any Problems Experienced

Interview Recommendations

Be honest

Answer questions thoroughly

Take advantage of the opportunity

Closing Conference & Post

Inspection

The inspector will identify the findings of the

inspection

Items of Concern and Violations

Next Steps

Letters

Follow-up & Resolution

Commonly Found Inspection

Violations & Concerns

Recordkeeping (Time, Date, Names, etc)

QA/QC

Noncompliance Notification

DMR Reporting Errors

Monitoring Frequency (Holidays)

Laboratory Procedures

Civil vs. Criminal

Any violation of the

permit

Known or should have

known that he/she

discharged a substance

contrary to Part 31, a

permit, order or rule of the

DEQ.

Intentionally making a false

statement, representation,

or certification in an

application or form

pertaining to the permit

(DMR/CMR)

Intentionally rendering a

monitoring device

inaccurate

DEQ Assistance

Informational Resource

If appropriate, we can:

Support work to improve your facility

Support increasing staffing

Help to mitigate complaints

Assist with some permit related modifications (reduced monitoring)

CANNOT act as a consultant

Operator Training Unit

Final Thoughts To A Successful

Inspection Process

Knowledge

Communication

Action

Any Questions?