How to Survive an EPA Audit

Similar documents
National Association of Wastewater Transporters (NAWT) Onsite Treatment Tank Pumping & Cleaning Code of Practice

Kentucky On-Site Septic Tank Servicing Regulations

A Visionary Review of the Land Treatment of Septage International Pumper & Cleaner Environmental Expo Louisville, Kentucky

State of Texas Biosolids Program Perspectives

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY WATER POLLUTION CONTROL FACILIITY PERMIT EVALUATION and FACT SHEET. April 15,2010

Example Petition for Exemption

SLUG CONTROL PLAN. Section A - Spills from Water-Using Process Areas

Public Utilities HILLSBOROUGH COUNTY GREASE HAULER PERMIT APPLICATION

Regulation of Commercial Waste Originators, Pumpers, Transporters, Processors, and Disposal Facilities

Authorized feedstocks, bulking agents, and additives and classification of composting facilities.

John Benson David Hanny Barton & Loguidice, P.C.

Appendix C SIP Creditable Incentive-Based Emission Reductions Moderate Area Plan for the 2012 PM2.5 Standard

REGULATIONS OF THE DEPARTMENT OF PROCUREMENT SERVICES FOR CLEAN DIESEL CONTRACTING

Bio Recycling North Ranch Lagoon Proposal

City of Alpena Septage Receiving Facility Operating Plan

SUBJECT: THIS IS THE ANNUAL GREASE DAMAGE PREVENTION PERMIT.

JEFFERSON COUNTY ENVIRONMENTAL SERVICES DEPARTMENT GREASE CONTROL PROGRAM FOOD SERVICE FACILITY GREASE CONTROL PROGRAM PERMIT APPLICATION

SPCC Regulation Integrity and Leak Testing Methods

AIR QUALITY PERMIT. Kennesaw State University - Marietta Campus

SCRAP TIRE FACILITY ANNUAL REPORT

Springfield Metro Sanitary District Grease Removal Form

This rule shall apply to any stationary source which is a major source of regulated air pollutants or of hazardous air pollutants.

The Importance of Biodiesel Meeting the ASTM D6751 Standard. Barbara E Goodrich Manager, Engine Fluids John Deere Power Systems 6 February 2008

Tune-up Information. Owners and operators of all biomass-fired and oil-fired area source boilers.

The following FAQs will help you in determining how to meet the new Federal medical certification requirements.

FINAL REPORT. Prepared for: ONTARIO MINISTRY OF THE ENVIRONMENT. Attention: Tony Ho. Prepared by:

Electrical Power Generator Use and Procurement Guidance

RFS2 Registration Requirements:

DEP7007CC Compliance Certification

Ohio Department of Transportation. Special Hauling Permits Section West Broad St. Columbus, Ohio Third Floor Mailstop #5140

Septage - Biosolids. Suggested Course Materials

ES Fueling Aircraft, Vehicles, and Auxiliary Equipment Document Identification Number

Septage Land Application Module

RFS2: Where Are We Now And Where Are We Heading? Paul N. Argyropoulos

Clean Taxicab Initiative Code Amendment to Provide an Extended Age Limit for Low Emission Taxicabs

Enhanced Interlock Technology

Septage Disposal Ordinance for Kent County

NOTES FOR THE APPLICATION OF FEMAS IN THE UNITED KINGDOM

1996, or for which modification is commenced on or before March 16, 1998, shall not exceed the

TITLE 252. DEPARTMENT OF ENVIRONMENTAL QUALITY CHAPTER 645. SEPTAGE PUMPERS AND TRANSPORTERS

CHAPTER 20.1 WASTEWATER HAULING. Section Definitions. For the purposes of this article, the following definitions shall apply:

AGRICULTURAL SOURCES (Adopted November 15, 2001; Amended September 16, 2004)

THE REPUBLIC OF LIBERIA Liberia Maritime Authority

The Road to Safety and Compliance Starts with You! ISRI DOT Self-Audit Checklist

What to Expect in a DOT Drug & Alcohol Audit

Section 12: Record Keeping Requirements. Minnesota Trucking Regulations

Safety Compliance Manual

DEPARTMENT OF TRANSPORTATION. Statutory Amendments Affecting Transportation of Agricultural Commodities and Farm Supplies

Summary of Agricultural Exemptions in Moving Ahead for Progress in the 21 st Century (MAP-21)

RICE NESHAP Frequently Asked Questions (FAQ)

Section 09: Commercial Driver s License. Minnesota Trucking Regulations

Permitting and Tracking Waste Haulers

3.1 Air Pollution Control Officer (APCO): as defined in Rule 1020 (Definitions).

TRANSPORTATION DEPARTMENT YEARS OF TRANSPORTATION REGULATION

Septage Treatment at Small Wastewater Treatment Plants

Michigan Renewable Energy Case Study

SPCC Marina Inspection Update Oklahoma Marina Association Inspector Tom McKay

Underground Storage Tank Guidance for Commercial Building Inspectors

1) Activity Description: Management of Petroleum Storage Tanks and Containers

RULE STATIONARY GAS TURBINES Adopted (Amended , ) INDEX

(2) An engine subject to this rule or specifically exempt by Subsection (b)(1) of this rule shall not be subject to Rule 68.

Abu Dhabi Department of Transport Application Form Non Objection Certificate (NOC)

Summary Data for Indiana Pesticide Law & Rule Development I N D I A N A P E S T I C I D E R E V I E W B O A R D M E E T I N G

The Energy Independence and Security Act (EISA): Proposed Changes to the Renewable Fuel Standard Program (RFS2)

CITY OF NEWTON Septage and Grease Trap Waste Disposal Program TABLE OF CONTENTS

Next Gen Biofuels Advisory

Underground Storage Tank Certification Examinations. Presentation to ASTSWMO November 27, 2007 UST SYSTEM OPERATOR CERTIFICATION

ORDINANCE AN ORDINANCE RELATING TO ON-SITE SEWAGE

STATE & LOCAL IDLING LAWS

Community Specifications - an EASA Perspective. Bryan Jolly ATM Rulemaking Officer 17 March 2011

2014 FCA Canada Inc. Windsor Assembly Plant [ANNUAL PUBLIC REPORT UNDER O. REG. 455/09]

The California Low Carbon Fuel Standard. John D. Courtis August 10-12, 2009

TIER 3 MOTOR VEHICLE FUEL STANDARDS FOR DENATURED FUEL ETHANOL

TRANSPORTATION & PACKAGING GUIDELINES GREATBATCH & ELECTROCHEM LITHIUM CELLS AND BATTERIES July 2011

City of Marlette. Wastewater Treatment Facility. Septage Receiving Plan

Streamlining Multiple Applicable Requirements

APPENDIX F PERFORMANCE COMPENSATION AND GUARANTEES

Motorcycle Safety Program Assessments

National Conference of State Legislatures Vehicle Idling Webinar

MARPOL Annex VI Emission Control Areas. CDR Ryan Allain U.S. Coast Guard Environmental Standards Division Washington, D.C.

SFI SPECIFICATION 1.3 EFFECTIVE: MAY 23, 2000 * PRODUCT: Nitro-Methane Drag Race Multiple Disc Clutch Assemblies

Safe Operating Procedure

9/17/2013 OVERVIEW WHAT RICE UNITS ARE IMPACTED? WHAT IS A RICE UNIT? EXAMPLES OF RICE UNITS WHY IS THE EPA REGULATING RICE?

The Introduction of Euro 5 and Euro 6 Emissions Regulations for Light Passenger and Commercial Vehicles

Septage Receiving Made Easy: Ten Things we have Learned

Air Permitting: Municipal Facilities with Emergency Generators

NSW Grain Harvest Management Scheme

for the DOT Safety Audit (SA) Compliance Review (CR) or New CSA Streamlined Review (SR)

Fuel for Marine Vessels

Notification for Underground Storage Tanks

Monthly Biodiesel Production Report

Major/Area Source. Speaker: Eric Swisher. 23rd Virginia Environmental Symposium April 11, Your environmental compliance is clearly our business.

RULE 4352 SOLID FUEL FIRED BOILERS, STEAM GENERATORS AND PROCESS HEATERS (Adopted September 14, 1994; Amended October 19, 1995; Amended May 18, 2006)

PFI Quality Assurance/Quality Control (QA/QC) Program for Residential/Commercial Densified Fuels

Permit Holder. Permitted Equipment

Section 1. Chapter 366 of NAC is hereby amended by adding thereto a new section to read as

ULS 2 Conversion Specialists: Incentives and Assistance for Cleaner Liquid Fuel Conversions

JrWf/! (t-. FEB

US oil production hits 15-year high: DEC 04, 2012

Metro and you, building together.

Transcription:

How to Survive an EPA Audit John Colletti U.S. Environmental Protection Agency, Region 5 February 27, 2008 312/886-6106 6106 colletti.john@epa.gov

Why Would I be Audited? Complaints Public perception Competition EPA becomes proactive

How do I Know I am Being Audited? An unscheduled visit from the local health department or state environmental agency Receive a CWA section 308 letter from EPA

What is a 308 Letter? A request for information Maximum of 5 years worth of records Failure to comply escalates to further enforcement

Records Requested 1] The location of the site where domestic septage is applied, either the street address, or the longitude and latitude of the site (available from the U.S. Geological Survey maps). 2] The number of acres to which domestic septage is applied at each site.

Site 1 10 acres Site 3 6 acres Site 2 8 acres John s Septage Disposal Sites 100 Farm Street Louisville

Record Requested (cont.) 3] The nitrogen requirement for the crop or vegetation grown on each site during the year, including the expected annual crop yield(s) used to establish the nitrogen requirement.

Determining the Allowed Annual Rate for Applying Domestic Septage to Non-Public Contact Sites Annual Pounds of Nitrogen Required Annual Application Rate for the Crop and Expected Yield (gallons/acre/year) = ----------------------------------------------- 0.0026 NON-PUBLIC CONTACT SITES INCLUDE AGRICULTURAL LAND, FORESTS, AND RECLAMATION SITES.

Record Requested (cont.) 4] The date of each domestic septage application. 5] The gallons of septage which are applied to the site during the specified 365-day period. 6] A certification statement.

Certification Statement "I certify under penalty of law, that the information that will be used to determine compliance with the pathogen requirements in [insert either 503.32(c)(1) or 503.32(c)(2)] and the vector attraction reduction requirements in [insert 503.33(b)(9), 503.33(b)(10), or 503.33(b)(12)] was prepared under my direction and supervision in accordance with the system designed to ensure that qualified personnel properly gather and evaluate this information. I am aware that there are significant penalties for false certification including the possibility of fine and imprisonment.

Record Requested (cont.) 7] A description of how the pathogen requirements are met for each batch of domestic septage that is land applied.

Pathogen Compliance Lime or no lime Harvesting restrictions Grazing restrictions Public access

Record Requested (cont.) 8] A description of how the vector attraction reduction requirement is met for each batch of domestic septage that is land applied.

Vector Attraction Compliance Injection Incorporation ph adjustment

Record Requested (cont.) 9] If using lime, records that indicate the ph requirements were met and bulk lime receipts.

ph Definition 40 CFR 503.31(g) ph mean the logarithm of the reciprocal of the hydrogen ion concentration measured at 25 o Centigrade or measured at another temperature and then converted to an equivalent value at 25 o Centigrade.

ph Correction Formula where: ph meas + ph cor = ph 25 o C ph cor = 0.03 ph units x (Temp o C meas 25 o C) 1.0 o C

Domestic Septage Regulatory Guidance A Guide to The EPA 503 Rule http://www.epa.gov/owmitnet/mtb/biosolids/septage_guide.pdf

Develop a Standard Operating Procedure (SOP) Discussion with farmer Speed of truck Addition of lime ph sampling Calibration of ph meter Temperature correction

Develop a Standard Operating Procedure (SOP) Flagging of site or GPS Storage Weather conditions Recordkeeping Certification Training of staff

Septage Enforcement Actions 2/08 State 308 Requests Penalty Orders Illinois 13 10 Indiana 4 1 Michigan 11 9 Minnesota 7 5 Ohio 29 16 Wisconsin 25 14

e to Septage id u g y s ea d Your fun an ent Options m e g a n a M g n Recycli e g a t Se p g n i l c y R ec Improve Septage Recycling for max benefits details inside Read a good book

Domestic Septage Regulatory Guidance A Guide to The EPA 503 Rule http://www.epa.gov/owmitnet/mtb/biosolids/septage_guide.pdf

Always look where you're going!

Always Spell Check your work.

Avoid Bad Habits