Oops…Where’s an Automatic Sampler?

A staff member of the Environmental Compliance Assistance Program recently received a call from a small wastewater facility. The facility had received a new permit but hadn’t fully reviewed it during public comment. Since the permit has been finalized, the facility was faced with a new sampling frequency and definition in their permit. The small facility was required to conduct a 24-hour composite sample weekly using an automatic sampling device. Because the facility had not read their permit and understood all the condition, a recent inspection found them out of compliance for not following the proper sampling procedures contained within their permits. In plain language, this meant that the facility could face a Notice of Violation until they were able to install an automatic sampling device.

Faced with tight budgets and being out of compliance, the operator was faced with several choices:

  • The facility as the permittee could request a temporary variance from KPDES program for the sampling requirement until an automatic sampler can be located
  • The operator could contact one of the two wastewater associations within the state to seek assistance in locating an automatic sampling device, knowing that they are still out of compliance in the interim until it is installed.
  • The operator could also contact neighboring facilities and ask if the facility could borrow a sampling device until a permanent one can be installed.

In the end, the lesson from this assistance request is to always read your permit and especially when it is in public comment. This is the time to make sure you understand your requirements and that you have the equipment necessary to comply or request changes to your draft permit before it becomes final.

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