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Chapter 3   Regulatory Reporting vs. Process Control

 

                 Analyses performed in the wastewater laboratory can be categorized by the use to which the data will be applied.  The first category of analyses is that performed as a result of a monitoring requirement imposed by the municipality, state or federal government often in support of a National Pollutant Discharge Elimination System (NPDES) permit.  Analyses fitting in this category are termed either “regulatory reporting”, or “compliance monitoring”.  The other category of analyses results from the need to obtain quantitative measures about some aspect of the plant operations which lead to decisions as to whether or not the plant is performing as designed.  These types of analyses are termed “process control”. 

                 The major difference between the two categories of testing exists in the test methods, although this is, for the most part, highly artificial.  For compliance monitoring, the laboratory must use methods approved by the regulatory agency.  The federally approved methods are published in Title 40, Code of Federal Regulations, Part 136 (40 CFR 136).  An updated version of 40 CFR 136 is published by the Government Printing Office on 1 July every year in the Federal Register.  These amendments are printed in 40 CFR 136 at the next annual update, but are effective as of the publication date of the Federal Register notice.  A major amendment was printed in the 31Jan1994 issue of the Federal Register.  It is reproduced in Table 1.  The EPA methods are from EPA manuals and the Standard Method citations are from the 18th Edition of Standard Methods for the Examination of Water and Wastewater.  A number of ASTM (American Society for Testing Materials) and USGS (US Geological Survey) methods are also approved, however they are rarely encountered in the municipal wastewater laboratory.  The Georgia EPD (Georgia Environmental Protection Division) accepts as approved methods those listed in Table 1.

                 Approved methods have several characteristics in common.  They are written, detailed, step-by-step instructions for the preparation of reagents and standards, calibrating the method, performing the test procedure and determining the accuracy and precision of results.  The chemistry of the method has been examined by experts and found to be suitable.  Possible and actual interferences are identified and avoidance measures specified.  The method has been verified by testing in a large number of laboratories.  In general, when methods are listed as approved which are not EPA or Standard Methods procedures, this means the chemistry of the method has been examined by a panel of experts and found to be suitable as a procedure for measurement of the tested parameter.  However, in most cases the directions provided by the manufacturer are unsuitable for establishing the analytical validity of the method, i.e. the test procedure must be fully calibrated by the analyst and other quality control measures taken to ensure the test is giving reliable results free from interferences and laboratory artifacts, whether the manufacturer mentions these or not.

 

 

                 The heart of the regulatory reporting process is the National Pollutant discharge Elimination System (NPDES) permit and the Discharge Monitoring Report (DMR), EPA Form 3320 -- I will insert  here soon---

  The information supplied on the monthly DMR relies upon a self-monitoring program.  The signature of the facility manager at the bottom of Form 3320 is a legal verification that the monitoring was conducted according to all applicable regulations and  further, that the person accepts full legal responsibility for the reported monitoring.  EPA and EPD have found that civil penalties are insufficient to enforce compliance with these regulations and have now turned to criminal prosecution with the attached threat (they have followed through in some cases) of felony convictions and penal system quality time.

                 It is not the legal responsibility of the equipment supplier nor the contract laboratory to ensure compliance.  It is the facility manager’s responsibility.  A close examination of regulations and contact with regulatory representatives on a continuing basis is the only way to obtain correct information about what is approved and what is not.  The laws are in place for the health and well-being of all people.  The intent and spirit of the law is to goad us into doing what we should be doing without threats.  The long term benefits are for us all.

                 Each facility which produces wastewater and is discharged to a receiving stream is required to have a NPDES permit, industries which do not discharge to a receiving stream are permitted by the State of Georgia to dispose of the wastestream by other methods.  In Georgia, the NPDES permits and other applicable permits (LAND APPLICATION, AIR QUALITY) are issued by the Environmental Protection Division of the Department of Natural Resources under the authority of the Georgia Water Quality Control Act (Georgia Laws 1964, p. 416, as amended).  The centerpiece of the permit is the table of “Effluent Limitations and Monitoring Requirements”.  An example of such a table is provided in Appendix II (real soon).  In 1955, EPD changed the standard language (boilerplate?) for NPDES permits to read as follows:

PART I

EPD is the Environmental Protection Division of the Department of Natural Resources of the State of Georgia

The Federal Act referred to is the Clean Water Act

The State Act referred to is the Water Quality Control Act (Act No. 870)

The State Rules referred to are The Rules and Regulations for Water Quality Control (Chapter 391-3-6)

 

A.     SPECIAL CONDITIONS

1.  Monitoring

The concentration of pollutants in the discharge will be limited as indicated by the table(s) labeled “Effluent Limitations and Monitoring Requirements”.  The effluent shall meet the requirements in the table(s) or the conditions in paragraph I.A.1.a, whichever yields the higher quality effluent.

a.  For 5 day biochemical oxygen demand (BOD₅) and total suspended solids (TSS), the arithmetic mean of values of the effluent samples collected during the month shall not exceed 15 percent of the arithmetic mean of values for influent samples collected at approximately the same times (or 85 percent removal).  For water pollution control plants followed by a polishing pond or consisting of a  waste stabilization pond, the 85 percent removal for TSS is not applicable.

b.  The monthly average, other than for fecal coliform bacteria, is the arithmetic mean of values obtained for samples collected during a calendar month.

c.  The weekly average, other than for fecal coliform bacteria, is the arithmetic mean of values obtained for samples collected during a 7 day period.  The week begins at 12:00 midnight Saturday and ends at 12:00 midnight the following Saturday.  To define a different starting time for the sampling period, the permittee must notify the EPD in writing.  For reporting required  by 1.C.2 of this permit, a week that starts in one month and ends in another shall be considered part of the second month.  The permittee may calculate and report the weekly average as a 7 day moving average.

d.  Fecal coliform bacteria will be reported as the geometric mean of the values for the samples collected during the time periods in 1.A.1.b. and 1.A.1.c.

e.  Untreated wastewater influent samples required by 1.B. shall be collected before any return or recycle flows.  These flows include returned activated sludge, supernatants, filtrates, and backwash.

f.  Effluent samples required by 1.B. of this permit shall be collected after the final treatment process and before discharge to receiving water.  Composite samples may be collected before chlorination with written EPD approval.

g.  A composite sample shall consist of __ subsamples collected at __ hour intervals for at least __ hours and shall be composited proportionately to flow.

h.  The permittee shall have a primary flow measuring device that is correctly installed and operable.  Secondary flow measurements must be made using a continuous totalizer and an indicating recorder.  Calibration of secondary instruments will be maintained to  10 % of the actual flow.  The head shall be measured manually to check the flow meter calibration at least once during each composite sampling period.  Records of the calibration checks shall be maintained.

I.  If the secondary flow instruments malfunction or fail to maintain calibration as required in 1.A.1.h., the flow shall be computed from manual measurements taken at the times specified for the collection of composite samples.

j.  Quarterly analyses required in 1.B. shall be performed in March, June, September and December.  Analyses required twice per year will be performed in June and December.  Analyses required annually will be performed in June.

k.  Some parameters must be analyzed to the detection limits specified by the EPD.  These parameters will be reported as “not detected” when they are below the detection limit and will then be considered in compliance with the effluent limit.  The detection limit will also be reported.

2.  SLUDGE DISPOSAL REQUIREMENTS

Sludge shall be disposed of in accordance with the regulations and guidelines established by the EPD and the Federal Act section 405(d), and the Resource Conservation and Recovery Act (RCRA).  In land applying nonhazardous municipal sewage sludge, the permittee shall comply with the general criteria outlined in the most current version of the EPD “Guidelines for the Land Application of Sewage Sludge (Biosolids) at Agronomic Rates” and the State Rules, Chapter 391-3-6-.17.  Before disposing of municipal sewage sludge by land application or any method other than disposal in a permitted sanitary landfill, the permittee shall submit a sludge management plan to the EPD  for written approval. This plan will become part of the NPDES Permit after approval.  The permittee shall notify the EPD of any changes planned in an approved sludge management plan.

If an applicable management practice or numerical limitation for pollutants in sewage sludge is promulgated under Section 405(d) of the Federal Act after approval of the plan, the plan shall be modified to conform with the new regulations.

3.  SLUDGE MONITORING REQUIREMENTS

The permittee shall develop and implement procedures to ensure adequate year-round sludge disposal.  The permittee shall monitor the volume and concentration of solids removed from the plant.  Records shall be maintained documenting that the quantity of solids removed from the facility equals the solids generated on an average day.  The solids removed from the facility shall be reported monthly as pounds per day with the Discharge Monitoring Report required under 1.C.2. of this permit.

All analyses performed to show compliance with the monitoring requirements of 40 CFR 503 must be conducted using EPA approved methods.  These methods are specified in 40 CFR 503.8.

4.  INTRODUCTION OF POLLUTANTS INTO THE PUBLICLY OWNED TREATMENT WORKS (POTW)

The permittee must notify EPD of:

a.  Any new introduction of pollutants into the POTW from an indirect discharger that would be subject to Sections 301 or 306 of the Federal Act if the pollutants were directly discharged to a receiving stream; and

b.  Any substantial change in the volume or character of pollutants from a source that existed when the permit was issued.

This notice shall include information of the quality and quantity of the indirect discharge introduced and any anticipated impact on the quantity or quality of effluent to be discharged from the POTW.

5.  EFFLUENT TOXICITY AND BIOMONITORING REQUIREMENTS

The permittee shall comply with effluent standards or prohibitions established by section 307(a) of the Federal Act and with chapter 391-3-6-03(5) of the State Rules and may not discharge toxic pollutants in concentrations or combinations that are harmful to humans, animals, or aquatic life.

If toxicity is suspected in the effluent, the EPD may require the permittee to perform any of the following actions:

a. Acute biomonitoring tests;

b. Chronic biomonitoring tests;

c. Stream studies;

d. Priority pollutant analyses;

e. Toxicity reduction evaluations (TRE); or

f.  Any other appropriate study.

The EPD will specify the requirements and methodologies for performing any of these tests or studies.  Unless other concentrations are specified by the EPD, the critical concentration used to determine toxicity in biomonitoring tests will be the effluent instream wastewater concentration (IWC) based on the permitted monthly average flow of the facility and the critical low flow of the receiving stream (7Q10).  The endpoints that will be reported are the effluent concentration that is lethal to 10 % of the test organisms (LC10) if the test is for acute toxicity, and the no observed effect concentration (NOEC) of effluent if the test is for chronic toxicity.

The permittee must eliminate effluent toxicity and supply the EPD with data and evidence to confirm toxicity elimination.  When approved by the EPD, all study plans and TRE plans will be come part of the requirements of this permit.

B.  EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

The Discharge(s) from the water pollution control plant shall be limited and monitored by the permittee as follows: The pH shall be not less than 6.0 SU (standard units) nor greater than 9.0 SU and shall be monitored on the final effluent by analyzing grab samples taken ____________.

Parameter	Discharge limitations mg/L (kg/day)		Monitoring Requirements
	Monthly Avg.	Weekly Avg.	Measurement Frequency	Sample Type	Sample Location

C.  MONITORING AND REPORTING

1.  REPRESENTATIVE SAMPLING

Samples and measurements of the monitored waste shall represent the volume and nature of the waste stream.  The permittee shall maintain a written sampling and monitoring schedule.

2.  REPORTING

All reports or information submitted in compliance with this permit or requested by EPD must be signed by a principal executive officer, elected official, or other authorized representative.  Required analytical results obtained by the permittee shall be summarized on a Discharge Monitoring Report form and any additional EPD specified forms.  Monitoring results shall be submitted to the EPD postmarked no later than the 15th day of the month following the end of the reporting period.  The EPD may require in writing that additional monitoring results be reported.  Signed copies of these and all other required reports shall be submitted to:  ____________.

3.  MONITORING PROCEDURES

Analytical procedures, sample containers, sample preservation techniques, and sample holding times must be consistent with the techniques and procedures listed in 40 CFR Part 136 for monitoring specified in 1.B.  EPA approved methods used must be applicable to the concentration ranges of the NPDES samples.

4. RECORDING OF RESULTS

For each required parameter analyzed, the permittee shall record:

a.  The exact place, date, and time of sampling, and the person(s) collecting the sample.  For flow proportioned composite samples, this shall include the instantaneous flow and the corresponding volume of each sample

, and other information relevant to document flow proportioning of composite samples;

b.  The dates and times the analyses were performed;

c.  The person(s) who performed the analyses;

d.  The analytical procedures or methods used;

e.  The results of all required analyses.

5.  ADDITIONAL MONITORING BY PERMITTEE

If the permittee monitors required parameters at the locations designated in 1.B. more frequently than required, the permittee shall analyze all samples using approved analytical methods specified in 1.C.3.  The results of this additional monitoring shall be included in calculating and reporting the values on the Discharge Monitoring Report forms.  The permittee shall indicate the monitoring frequency on the report.  The EPD may require in writing more frequent monitoring, or monitoring of pollutants not specified in this permit.

6.  RECORDS RETENTION

The permittee shall retain records of:

a.  All laboratory analyses performed including sample data, quality control data, and standard curves;

b.  Calibration and maintenance records of laboratory instruments;

c.  Calibration and maintenance records and recordings from continuous recording instruments;

d.  Process control monitoring records;

e.  Facility operation and maintenance records;

f.  Copies of all reports required by this permit;

g.  All data and information used to complete the permit application; and

h.  All monitoring data related to sludge use and disposal.

These records shall be kept for at least three years.  Sludge handling records must be kept for at least five years.  Either period may be extended by EPD written notification.

7.  PENALTIES

 Both the Federal and State Acts provide that any person who falsifies or tampers with any monitoring device or method required under this permit, or who makes any false statement, representation, or certification in any record submitted or required by this permit shall, if convicted, be punished by a fine or by imprisonment or by both.  The Acts include procedures for imposing civil penalties for violations or for negligent or intentional failure or refusal to comply with any final or emergency order of the Director of the EPD.

 

PART II

A.  MANAGEMENT REQUIREMENTS

1.  FACILITY OPERATION

The permittee shall maintain and operate efficiently all treatment or control facilities and related equipment installed or used by the permittee to achieve compliance with this permit.  Efficient operation and maintenance include effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance procedures.  Back-up or auxiliary facilities or similar systems shall be operated only when necessary to achieve permit compliance.

2.  CHANGE IN DISCHARGE

Any anticipated facility expansions, or process modifications which will result in new, different, or increased discharges of pollutants requires the submission of a new NPDES permit application.  If the changes will not violate the permit effluent limitations, the permittee may notify EPD without submitting an application.  The permit may then be modified to specify and limit any pollutants not previously limited.

3.  NONCOMPLIANCE NOTIFICATION

A permittee who does not comply with any permit effluent limit shall provide the EPD with an oral report within 24 hours from the time the permittee becomes aware of the circumstances, followed by a written report within 5 days.  The written report shall contain:

a.  A description of the noncompliance and its cause;

b.  The exact dates and times of noncompliance or, if not corrected, the anticipated time the noncompliance is expected to continue; and

c.  The steps taken to reduce, eliminate, and prevent recurrence of the non complying discharge.

4.  ANTICIPATED NONCOMPLIANCE NOTIFICATION

The permittee shall give written notice to the EPD at least 10 days before:

a.  Any planned changes in the permitted facility; or

b.  Any activity which may result in noncompliance with the permit.

5.  OPERATOR CERTIFICATION REQUIREMENTS

The person responsible for the daily operation of the facility must be a Class __ Certified Operator in compliance with the Georgia State Board of Examiners for Certification of Water and Wastewater Plant operators and Laboratory Analysts Act, as amended, and as specified by Subparagraph 391-3-6-.12 of the Rules and Regulations for Water Quality Control.  All other operators must have the minimum certification required by this Act.

6.  LABORATORY ANALYST CERTIFICATION REQUIREMENTS

Laboratory Analysts must be certified in compliance with the Georgia State Board of Examiners for Certification of Water and Wastewater Plant operators and Laboratory Analysts Act, as amended.

[Further information is provided on Industrial Pretreatment programs and requirements]

 

                 EPA Form 3320 must be completed each month and submitted to the Georgia EPD by the 15th of the next month.  The 3320 will report the monthly average and the daily maximums for each parameter on the NPDES permit.  Most facilities monitor on a daily basis for each parameter.

                 The purpose of process control testing is to generate data for consumption at the individual plant.  Whichever method is deemed suitable by the plant supervisor is appropriate to use.  In-line automatic data loggers, such as temperature, pH, turbidity, residual chlorine and DO electrodes, are frequently used for process control.  An example of process control testing needs for each major plant operation follows:

          Influent                                 Primary Treatment

                 Flow                                        Raw sludge total solids

                 BOD₅                                      Raw sludge volatile solids

                 Total suspended solids         Primary effluent BOD₅

                 Volatile suspended solids     Total suspended solids

                 COD                                       Volatile suspended solids

                 Phosphorus                            Ammonia nitrogen

                 pH                                           Phosphorus

                 Ammonia nitrogen                 Sludge pumped

          Secondary Treatment (Activated Sludge)                Secondary Treatment (Trickling Filter)

                 Settleable solids                    Return Sludge

                 Aeration tank suspended solids                        Waste sludge

                 BOD₅                                                                Hours wasted

                 Dissolved oxygen                  Effluent ammonia nitrogen

                 Air supplied

                 Microorganism identification

          Solids Handling                   Plant Effluent

                 Digester total solids               BOD₅

                 Digester volatile solids          Total suspended solids

                 Volatile acids                           Volatile suspended solids

                 Alkalinity                                  COD

                 Dry tons of dewatered sludge                           Phosphorus

                 Dewatered sludge total solids                           Ammonia nitrogen

                 Cubic yards of sludge and ash hauled                                   pH

                                                       Dissolved oxygen

                                                       Temperature

                                                       Residual Chlorine

                                                       Fecal coliform

 

          When process control procedures are performed in the laboratory, frequently the process control result is also reported as a compliance monitoring requirement, however on a less frequent basis.  Rather than perform the official method for compliance monitoring and a non-approved method for process control, it is much easier and less confusing to simply always perform every test by the approved methods.  Further, Georgia EPD states that if a parameter is listed on the NPDES permit for compliance monitoring, the approved method must be used each time the parameter is measured and also all measurements of the parameter made during the month must be reported to Georgia EPD (I.C.5).  Georgia EPD allows no distinction between compliance monitoring and process control for permit parameters.  Process decisions made in the plant can have far-reaching economic and public health implications.  Consideration of the impact that these decisions can have, which in many cases are dependent upon process control test results, leads one to the conclusion that the best data can be related to the best decisions.  Thus the approved method would again be the procedure of choice.

 

 

Questions for Chapter 3

 

1.  List the EPA and Georgia EPD approved methods for Nitrate/Nitrite-N and indicate where these methods can be found.

 

2.  List the data which the NPDES permittee must record for each required parameter analyzed.

 

3.  List the 8 groups of records which the permittee must retain.

 

4.  How long must records be retained which demonstrate NPDES compliance?

 

5.  Describe where EPA publishes the lists of approved methods and how are they updated.

 

6.