Industrial Pretreatment Inspection Program
By Rodrigo Moriones, Natural Resource Specialist II
A good inspection program is essential for a successful Industrial Pretreatment Program (IPP). A good inspector is one who is able to deal fairly, effectively and tactfully with Industrial Users (IUs), regulators and the public. The Broward County Water and Wastewater Services’ IPP Enforcement Section conducts various types of inspections in the regulation of its industrial users which are discussed in the following paragraphs.
The Industrial Wastewater Survey is used to identify and locate all possible industrial users subject to the pretreatment program, and to identify the volume and character of pollutants discharged by these users.
- The survey allows the utility to determine which users need to be regulated by the program and, therefore, affects the resources dedicated to the program
- Provides the basis for determining which users are subject to categorical pretreatment standards; and
- Informs the utility of the character of the wastes being discharged to the WWF, thereby providing the basis for local limits for specific pollutants
A Permitting Inspection is conducted to verify data reported in the wastewater discharge permit application and to designate a sampling point. It is a special inspection conducted when a facility is initially permitted or the permit is renewed.
An Annual Inspection is undertaken to assure compliance with the requirements of the U.S. Environmental Protection Agency (EPA) Industrial Pretreatment Program in which a permitted facility must be inspected at least once per year. Inspectors determine if a facility is in compliance with their wastewater discharge permit by reviewing:
- Production processes
- Wastewater treatment processes
- Monitoring equipment
- Hazardous material and waste storage areas
- Documentation and records
During a Compliance Verification inspection, the inspectors determine whether:
- The sampling location specified in the permit is adequate for the collection of a representative sample of the wastewater
- The user's sampling technique is adequate to ensure the collection of a representative sample
- The user's permit monitoring requirements will yield representative samples
After these initial inspections, a Follow up Inspection may be conducted to verify that required actions from the previous inspection (if applicable) are fulfilled and that the facility continues to be in compliance.
The Enforcement Section also performs Complaint Inspections as needed due to odor or illegal discharges brought to our attention by the public or other regulating agencies. Finally, a Closure Inspection is done when an IU ceases discharging, or is in the process of removing a regulated process and/or ceases operation in our service area.
In summary, the objectives of industrial pretreatment inspections are to:
Collect information and obtain samples to evaluate industry compliance with local, state and federal pretreatment standards and requirements.
Identify changes in industrial processes that may affect the quality of the industrial wastewater discharge and subsequent permit limitations.
Talk with and answer questions of industrial representatives, thus maintaining a cooperative as well as a regulatory presence with the industrial community.
Verify information submitted to the Control Authority by the IU.
The benefits of inspections are many, including establishing good rapport and creating cooperation between regulators and IUs. Inspectors play a crucial role in the success of the Pretreatment Program.
Importance of Public Communications and Outreach
By Gregg Teufel, Special Projects Coordinator II
You might ask, “Why is public communications important for a water and wastewater utility?” The answer is, “A good public communications program can help a utility such as Broward County Water and Wastewater Services (WWS) build credibility with customers, lawmakers, stakeholders and the media through a program that develops proactive stories and responds to the media in a courteous and timely manner.” Public communications can help build goodwill in the community through programs that reach out and involve people in activities, special events and community-related services. Finally, a good public communications program can help bring important knowledge to our customers and key stakeholders who know our story from advisories, news releases, community discussions, ads, bill inserts and other efforts such as this first edition newsletter.
The WWS IPP Enforcement Section is constantly evolving to address new challenges that face our utility, stakeholders and customers. Through use of an effective public communications program, we will continue to reach out to the community with a positive and proactive approach.
In keeping with our proactive approach, The Pretreatment Press staff members encourage participation from its readers. Please submit your comments, suggestions or subject ideas you would like to see addressed in a future issue to firstname.lastname@example.org. We look forward to hearing from you.
Permitting Industrial Users in Broward County
By Denise Ramos, Natural Resource Specialist II
Identification of the Industrial Users (IUs) within the Broward County Water and Wastewater Services (WWS) service area is an extremely important compliance facet of the Broward County Industrial Pretreatment Program (BCIPP).
The initiation of industrial user wastewater permitting process may result from a variety of reasons and/or sources:
- BCIPP staff carrying out an Industrial Waste Survey and locating a new industrial user
- BCIPP staff carrying out a follow up investigation related to the hauled waste program
- A new industry moving into the service area and submitting a Wastewater Discharge Application.
- Information provided to BCIPP from large users.
Most typically the permitting process would begin with the Wastewater Discharge Permit Application which must be submitted to WWS enforcement staff along with a $75 application fee. Each application provides the BCIPP with vital client information regarding the facility’s name, address, contact information, type of industrial process, number of employees, industrial category, chemicals used at the facility and the amount of water used and discharged from the facility. All of this information is entered into the BCIPP tracking database. Fiscal Operation at WWS is also provided with the client information to ensure that an account has been or will be set up for the potential permittee.
Using the information submitted by the IU in the wastewater discharge permit application, in conjunction with the information garnered from a facility pre-permitting inspection by BCIPP permitting and inspection staff, a Temporary Operating Permit (TOP) document may be issued to the industrial user.
The TOP is usually issued for a period of 90 days, during which time the facility is allowed to discharge to the collection sewer system and the TOP delineates any additional information that is required to be submitted to WWS, the timeframe for submission of this information including, baseline monitoring results, water bills and any other pertinent construction related information. During this time any necessary construction and or installation of primary sampling devices and additional pretreatment equipment may take place.
If it is determined that a final industrial user permit is required, the information obtained from the wastewater discharge permit application, the baseline monitoring results, facility inspections and the pretreatment regulations are all utilized in the classification of the industry.
Following classification of the industry as categorical or non-categorical, existing source or new source, assignment of the relevant type or types of permit limits takes place. The tracking database is updated with all pertinent client and compliance related information along the way.
This document is reviewed by Enforcement Section staff and management, and ultimately approved and signed by the WWS Director of Operations Division.
The Permitting Process for Waste Haulers in Broward County
By Chad Zurko, Secretary
Broward County’s Water and Wastewater Services (WWS) Enforcement Section regulates two programs: the Hauled Waste Program and the Industrial Pretreatment Program. This article will focus on the permitting process as it relates to the Hauled Waste Program. Broward County Permitted Waste Haulers are allowed to dispose of waste at the Broward County Septage Receiving Facility (BCSRF) located at 3100 N Powerline Road in Pompano Beach. This permitting process has two parts.
First, potential hauled waste permittees must apply for and obtain a license to transport waste within Broward County, from the Broward County Environmental Protection and Growth Management Department (EPGMD). The permittee will specify which categories of waste they will be transporting on the application they submit to EPGMD. This license provides information about the business and lists the categories of waste the company will be disposing (i.e. sludge hauling, septic, grease trap, sewage from lift stations or storm drain cleanout). The license also includes an inventory of decals and tag numbers for all trucks that will be brought to the BCSRF. These licenses and decals are typically valid for two years.
Once the permittee has received a waste transporters license, then the permittee can submit a waste hauler discharge permit application to WWS, requesting approval to discharge the same categories of waste at the Broward County Septage Receiving Facility. The WWS waste hauler discharge permit application must be filled out completely with contact information, waste types, and most importantly, EPGMD decal number, vehicle make, model, year and capacity (in gallons) for all trucks that will be discharging at the BCSRF. The application must be signed and returned to WWS pretreatment program staff along with two separate checks, one for $75, which is the application fee and another check as a deposit. The amount of the deposit is dependent on the number of vehicles listed on the permit application.
WWS Fiscal Operations Division is provided with the client information for the new customer by Broward County Enforcement Section staff. Then Fiscal Operations staff enters the new hauler client information into the billing system and issues the permittee a new account number for billing purposes, which is included in the permit document. After this step has been completed, the hauler may be allowed to discharge upon request. A hard copy of the Waste Hauler Permit document is generated, signed by management and mailed to the hauler. Included in the mailing packet are Waste Tracking Forms for each truck decal that appears on the permit document and a copy of the most current BCSRF disposal policies and procedures. These Waste Tracking forms must be filled out and submitted by the company’s driver each time a load is brought to the BCSRF.
It is important to note that our permits are valid for approximately two years. However this timeframe might not always coincide with the period that the Waste Transporter License/decals are valid. Therefore, haulers and staff must ensure that the decals on each truck are current and match the number on the Waste Tracking Form. Also, the waste hauler should notify us if they are adding a new vehicle or replacing an old one with a new decal number. In this case a new permit application would need to be filled out and a revised permit issued.