It is a fact—most people never think about sewage. They flush the toilet or empty out the sink without a thought. However, if you own, operate, or manage a wastewater treatment facility, you should learn some basic strategies to keep you out of trouble.
WARNING—The FDEP holds you, the owner, responsible for compliance with all terms and conditions of the permit. This responsibility CANNOT be delegated!
To stay out of trouble you need to know:
- When to renew your permit
- Who you need on your team
- What documentation you need to have available
Permit Renewal
In Florida, your wastewater treatment facility is regulated by the Florida Department of Environmental Protection (FDEP). This agency has its authority granted by the United States Environmental Protection Agency (USEPA) and the Florida Statutes.
As such, the FDEP has the authority to regulate the operations of the wastewater treatment facility and require that the facility’s operating permit be renewed every 5 years. It is very important that a permit renewal application be submitted in a timely manner. Submitting the permit application on time protects you by guaranteeing that the permit will be continued and not expire.
This is important, because if your permit is administratively continued it means that your permit will not expire regardless of any complications that may arise during the permitting process. Complications during permitting (which may delay the issuance of the new permit) arise from time to time. Having continuance (timely permit submittal) will guarantee that your permit will not expire.
Let me explain…
According to the FDEP, a permit application needs to be submitted between 365 days to 180 days prior to its expiration date for it to be considered timely. If the permit application is submitted with less than 180 days to expiration date, the permit will not be automatically continued after expiration date.
If there are delays and complications during the permitting process and the application is not complete by the permit expiration date, the permit expires and your wastewater facility will be operating without a permit.
By Florida Law, the FDEP then has to take legal action against you to resolve the problem. This is typically accomplished with a Consent Order. A Consent Order will typically require that you hire an attorney and that your engineer do more work. Additionally, there are fines and penalties associated with a Consent Order.
So, it is in your best interest to start the permitting process by hiring a professional Environmental Engineer at least 270 days before the permit expiration date. And if the wastewater treatment facility is experiencing problems even sooner.
Who’s On Your Team
Experienced wastewater treatment facility owners, operators and managers understand that there are 3 different roles in running a wastewater treatment facility:
- Licensed Wastewater Operator
- Licensed and Qualified Contractor
- Professional Environmental Engineer
Having each of these roles fulfilled by separate entities provides you, the owner, the checks and balances needed for a cost-effective and quality operation—without the self-interests of any one party affecting your pocketbook.
Licensed Wastewater Operator
This is the person with hands-on, day-to-day experience. Most owners use the services of a contract operator. This is a company that you hire to take on the day-to-day operation of the facility.
The permit requires that a licensed operator visit the facility every day. Depending on the size of the facility, the amount of time that is required for the operator to be on-site varies. For small facilities, it is typically one-half hour per day. On larger facilities, it can be 3 hours or more per day.
What Does Operator Do?
The operator fills out a logbook every time he visits the facility. The log book is a record of when the operator arrived and the facility, when he left and what actions were taken during the visit and the results. The operator also performs various tasks required by the permit and operations protocol. At a minimum, the following information is required to be recorded by the permit:
- Daily flows
- Acidity of the wastewater
- Chlorine residual concentration
- Description of any abnormal events
- Rainfall amounts
From time to time other parameters are required to be recorded. For instance, some of these may be required on a monthly basis and on an annual basis. At larger facilities, the required parameters that need to be recorded may increase in amounts and frequency.
Discharge Monitoring Reports (DMR)
Every month the operator is required to fill out and submit to the FDEP a DMR. The DMR needs to be signed by the Permittee. However, this is the only time that the Permittee may delegate this authority to the operator. This requires a legally binding formal authorization form. It should be noted, though, that the Permittee is held accountable by the FDEP for any errors and omissions in the preparation and filing of the DMR and collection of any of the required information. The operator is typically the one that does all of the routine maintenance and repairs on the plant and equipment.
Professional Environmental Engineer
You should develop a relationship with a professional environmental engineer that has experience with permitting and design of “wastewater treatment facilities”. The Professional Engineer is the only person authorized by the “Florida Statutes” to make any changes to the operations or configuration of the wastewater treatment facility. Additionally, the professional engineer is required for renewing the permit application. An experienced professional engineer will also help you avoid costly mistakes.
Typically a professional environmental engineer is hired during the permitting process, or when the facility is significantly out of compliance. When your facility is significantly out of compliance the FDEP will require that a professional environmental engineer develop a report addressing the problems and providing recommended solutions.
Therefore, you should develop a relationship with an experienced professional wastewater engineer that you can trust. Then the management of your wastewater treatment facility will be smoother and it will save You money in the long run.
The role of the professional environmental engineer is to advise the owner if the facility is being operated in accordance with the permit and standard operations procedures. A professional engineer experienced in wastewater treatment facilities will be an invaluable asset to the owner. The engineer can assist the owner and operator in developing economical solutions to complicated situations that arise. The engineer will also be instrumental in keeping the owner from making unwise decisions in the operations of the WWTF.
Qualified and Licensed Contractor
A contractor is generally needed when more than routine maintenance is required. Typically when tanks and equipment need to be added to the facility you will need a Licensed Contractor. Although a contractor may not play as large a role as the operator or the engineer, having a qualified and licensed one is good during construction-related activities. Your engineer can help you choose the right contractor for the job.
One of the biggest problems on wastewater construction projects is that a contractor is chosen based solely on price without regard to qualifications. Many times the owner doesn’t know where to turn to and hires unqualified and unlicensed contractors because they’re the ones he knows.
In Florida, the FDEP issues a construction permit to the owner. This is unlike most building departments which issue the construction permit to the licensed contractor. Therefore, many times, unlicensed contractors submit bids and are considered for a project even though they are unqualified and unlicensed. This can result in the owner paying twice for the job, either over the short term or long term due to shoddy work practices and poor workmanship.
Required Documentation
Your wastewater treatment facility operating permit requires that you keep certain documentation on-site. This documentation needs to be readily available to a FDEP inspector. The documentation needs to be updated monthly so that the most current 36 months of information is available.
Your Permit Requires That You Have Copies of the Following Documentation:
- Discharge Monitoring Reports (DMR)
- Water Quality Analysis
- Copy of Operating Permit
- O & M Manual
- Facility Plans
- All Correspondence with FDEP
- Copy of Current Operator’s License
- Current Copy of Meter Calibration
Maintaining a file with this information does not have to be an onerous task. Your operator and engineer should provide you with copies of all documents filed on your behalf and all correspondence with the FDEP. You can file all of these documents in a 3-ring binder. The binder needs to be updated every month.
