NPDES Primer for Executive Officers of Wastewater Facilities

Indiana Department of Environmental ManagementOffice of Water Quality

Compliance Branch

Presented by

Rick Roudebush

Indiana Dept. of Environmental Management

July 17, 2006

Important Acronyms to Know

IDEM = Indiana Department of Environmental Management

NPDES = National Pollutant Discharge Elimination System, permit regulating a point source to discharge into waters of the United States

DMR = Federal Discharge Monitoring Report MRO = State Monthly Report of Operations CSO = Combined Sewer Overflow (storm and

sanitary sewer drains)

When in Doubt…

Call IDEM ! Toll-free Enviroline: 1-800-451-6027 Indianapolis: (317) 232-8670 North West Office, Merrillville: (219) 757-0265 North Central Office, South Bend:

(574) 245-4870 South West Office, Petersburg:

(812) 380-2305

Direct Contacts:

Wastewater Inspectors Section Chief: (317) 234-2579

Operator Assistance Phil Preston: (317) 232-8728

Bypass/Overflow/Compliance Gary Starks: (317) 232-8694

Operator Certification Heather Tippey-Pierce: (317) 233-0479

Know what’s going on !You can delegate the authority to sign and submit reports, but you can NOT delegate

your responsibility.

You are responsible for what is going on at your treatment plant.

Certified Operators

Every plant must be under the supervision of an operator holding a valid certification.

Notify IDEM when you change operators. Have clear roles, duties and communication

between owner and operator. Many violations are the result of poorly

defined duties and expectations between the facility owner and the operator.

Monthly Reports

Permit requires submittal of two (2) reports Federal Discharge Monitoring Report (DMR) State Monthly Report of Operations (MRO) Certified operator completes and signs the

MRO while the designated official signs the federal DMR and the MRO.

Must be post-marked by the 28th of the month following sampling.

Laboratory Testing

Operator is responsible for the collecting of water samples for testing to determine whether you are meeting effluent limits.

Also samples flow coming into the plant and at various stages of the treatment process to evaluate and adjust treatment plant operations to meet the permit limits.

Records Retention

All records and information resulting from monitoring activities as required by the permit, shall be retained for a minimum of 3 years.

In cases where the original records are kept at another location, a copy of all such records shall be kept at the facility.

IDEM inspectors will ask to review these.

Compliance Schedules

Permits or Agreed Orders may have compliance schedules.

Compliance schedules require completion of activities and submittal of written reports to IDEM on a planned timetable.

It is your responsibility to make sure the required activities occur and for submitting all required reports to IDEM.

Operation & Maintenance

Treatment plants and collection systems must be maintained in good working order and efficiently operated.

Adequate staffing by duly qualified personnel must be provided to carry out the operation, maintenance and testing functions to ensure permit compliance.

Sludge Disposal

Sludge (Biosolids) must be routinely removed from the treatment plant.

Strict requirements regarding sludge disposal must be documented.

Notify IDEM prior to any changes in sludge use or disposal activities.

Bypass/Overflow Reporting

Any discharge from a sanitary or combined sewer system other than a permitted CSO event must be reported to IDEM by telephone, (317) 232-8694, within 24 hours and in writing within 5 days.

Most people meet both of these requirements by faxing in a written report on IDEM’s fax form within the first 24 hours.

This form can be found at:http://www.in.gov/icpr/webfile/formsdiv/48373.doc

If there is a significant danger to human health or the environment, it must immediately be reported to IDEM’s spill line: (888) 233-7745.

! Health Hazards !

If excessive discharges are occurring then enforcement actions may be initiated.

Failure to properly report any overflow is considered a serious violation and is likely to result in immediate enforcement action!

Bypass Consequences

Collection Systems

Require regular ongoing maintenance. Most common problem is excessive clear

water getting into the sewer. Frequent source of clear water is illegal

connection of sump pumps and roof drains to the sanitary sewer by homeowners.

Penalties

Violations may result in monetary fines. Responsible parties knowingly making false

statements or falsifying written reports (letters, DMRs, MROs, etc.) may result in both fines and imprisonment of the individual.

Permit Renewal

NPDES Permit renewal applications must be submitted six months prior to the expiration date of the current permit.

IDEM regularly sends out renewal notices to pending facilities 10 months prior to the permit expiration date.

WWTP & Records Access

Advance notice of inspections not provided by IDEM under normal circumstances.

You must make arrangements for our inspectors to have access to your facility and records during normal working hours.

Annual Fees

Every permitted facility will receive an annual permit fee bill according to the Indiana State Rules.

Most facilities have a standard base fee amount according to the facility classification plus a flow based amount.

Annual bills are mailed in early January and are due 60 days after the bill date.

Late fees will be applied after 60 days with failure to pay leading to enforcement action.

Common Reporting Problems

Federal DMR arrives at IDEM late. DMRs must be postmarked by the 28th of the month following the month in which the sampling occurred.

If you have problems please document them either in the comments section at the bottom of the DMR form and\or in an attached letter.

DMR is not fully completed

Not checking the “No Discharge” box when applicable

Leaving blank spaces (open boxes)

Authorization incomplete

No signature No date signed No telephone number for signatory authority Signature is not of person registered with

IDEM as having the authority to sign.

Required Forms

IDEM has a variety of state forms for different types of wastewater plants. These may be referenced as:

Monthly Report of Operations (MRO) Monthly Monitoring Reports State Discharge Monitoring Reports (DMR)

Every facility is required to submit state forms along with the required federal DMR forms.

Incomplete \ Missing MRO

No flows listed, but effluent samples reported No influent data No Certified Operator signature No Authorized Official signature No Certified Operator certification number No date Form not submitted with DMR Self-generated forms are missing fields

Incorrect DMR form submitted

DMR from wrong month – Bar Code Self-generated DMR form errors:

Incorrect parameter codes Missing parameter or other key elements Poor organization or placement Wrong bar code

Data Calculation\ Reporting Errors

MRO data was not correctly transferred to DMR

Incorrect calculation methods used for averages, percent removals, geometric means, etc.…

If only one sample is taken in a monitoring period, failure to report that value as both the monthly average and maximum.

Using units other than those required by the permit.

The End