Environmental regulations

Question 1

You are out of compliance with your wastewater discharge. What is your first step in responding to the violation and who is one of your biggest resources in dealing with this problem?

Answer 1

• Shut down
• Call the city
• Resource is our chemical/environmental contact

Question 2

Your sludge is tested and is labeled as hazardous. What would be your next couple of steps to handle this problem?

Answer 2

• Have sludge retested. Document and dispose of the sludge appropriately using a licensed contractor.
• Work to determine the source of the problem and fix it

Question 3

If the city and county effluent discharge requirements in your area differ from one another, which one will supersede?

Answer 3

• The city requirements will supersede the county requirements. Local POTW’s can impose requirements that exceed those of the county, state or federal. They must meet the minimum but can require stricter requirements.

Question 4

What is the difference between a compliance limit and a surcharge limit?

Answer 4

• Compliance limit- is an absolute limit. If you exceed this it results in a non-compliance violation.
• A surcharge limit- not an absolute- will not result in a violation. The more surchargeables discharged (BOD- biochemical oxygen demand) and TSS (Total suspended solids) the higher the bill will be.

Question 5

If you cannot send water to your Dissolved Air Flotation system because of equipment downtime/failure, what are your options for discharging the wastewater?

Answer 5

• Utilize emergency holding capacity of the pits and EQ tank while attempting to resolve the DAF
• If unable to fix before capacity in the tanks reach their limit. You must shut down until the DAF is fixed.

Question 6

If you have a chemical spill that enters your wastewater treatment system, what steps must you follow?

Answer 6

• If the spill enters the wastewater treatment system this is now called a slug. This must be reported to the POTW (publicly owned treatment works) immediately.
• If the spill is potentially reactive, evacuate the facility and contact emergency services.

Question 7

What is a universal waste and how are they regulated?

Answer 7

• It is widely generated waste by individuals and businesses. Like batteries, fluorescent lights.

Question 8

What is SARA Title III Tier II Requirements? What and when are you required to report?

Answer 8

• SARA is a federal law administered by the State and local government. The purpose is for business and industry to report the chemicals in their facility. Communities have a “right to know” about the chemicals in their area.
• Chemical reporting is required for those chemicals where the maximum storage exceeds 500 pounds and for those “extremely hazardous substances” that exceed a chemical specific threshold poundage. In the case of Cintas, all bulk products exceed 500 pounds and must be reported.

This must be sent to the city annually or sooner if there is a change or add in the chemicals used.

Question 9

How long must you maintain a copy of your compliance records (wastewater analytical data, notifications from the city, etc.)

Answer 9

• Indefinitely

Question 10

If shop towels with ink are sold at your location; who is permitted to process them?

Answer 10

• Cintas does not process ink towels. We must ship to an approved vendor, we use Hunt cleaners, to process them.

Question 11

Where in your facility should ink shop towels be stored for shipment to approved vendor to process?

Answer 11

• Dirty and clean product is not allowed to be stored in the building and is stored under our carport, 20 ft from the building.

Question 12

What is included on the compliance checklist for government laws and regulations?

Answer 12

• R-7000- exhibit A

Question 13

After analyzing your wastewater for the parameters identified within your permit, what are you required to submit the the city?

Answer 13

Critical checklist
Report all testing on site
Discharge and pretreatment logs