FDEP State Pretreatment Update

1. FDEPState PretreatmentUpdate Industrial Pretreatment ProgramSam Jinkins, Pretreatment Specialist

2. Overview • Introduction - Ms. Randi Peddie • Inspections - FOG and SSOs • Rule Revision - Program document updates • Annual Reports/DMR Requirements • Program Assignments

3. Introduction • New Addition to FDEP’s industrial pretreatment Staff - Ms. Randi Peddie

4. Inspections, FOG, and SSO’s • SSO list will be reviewed during all PCI’s and PPA’s • Reported sanitary sewer overflow list • Department is updating the inspection forms to specifically require reporting for any fats, oils, and grease related issues….Stay tuned.

5. Chapter 62-625 Revisions • Existing legal authority and other program documents must be updated to incorporate the May 10, 2010 rule revisions. • Updates of program documents will be required when: • Program modification is requested • Next inspection • WWTF discharge permit renewal – AO may be issued

6. Chapter 62-625, F.A.C. Revisions • Sewer Use Ordinance (SUO) • Review the EPA Model SUO for optional and required streamlining changes • Each section of this model indicates if optional or required • These are noted before or after each section

7. Chapter 62-625, F.A.C. Revisions • Other program documents (ERP, PIP, etc.) • Ensure definitions are updated – e.g. most ERPs include the SNC requirements • Include the optional provisions – e.g. replace SUO in the PIP, include enforcement responses in ERP matrix • Multijurisdictional Agreements (MJA) – contributing jurisdictions must update SUO

8. Chapter 62-625, F.A.C. Revisions • Common Problems • Multiple Changes to SUO due to permit renewal that includes a local limit re-evaluation • CA wish to reference local limits in the SUO and remove the concentration based local limits • references to optional provisions often taken out of context and are removed • Best Management Practice (BMP) example

9. Where should BMPs go in SUOs?

10. Annual Pretreatment Reports - DMR • Pretreatment (Monitoring Code PRT-I, PRT-E, and PRT-R) discharge monitoring reports (DMR) must be included in the Annual Industrial Pretreatment Report • Submit the AR, including the DMR, to the IPP program in Tallahassee • Submit signed original to the Department IPP in Tallahassee • CC the District Office

11. Annual Pretreatment Reports - DMR • Common Problems • Exceedances - WQS, groundwater standards, permit limits, etc. must reported in both the No. Ex. column and Section 3 of the annual report • Conventional pollutants (BOD, cBOD, oil and grease, nutrients) not reported • DMRs – Not submitted, submitted to the District office, or submitted separately from the AR

12. Annual Pretreatment Reports - DMR • Signatory requirements for AR • “Reports submitted to the Department by the control authority in accordance with subsection (8) above must be signed by a principal executive officer, ranking elected official, or other duly authorized employee. The duly authorized employee must be an individual or position having responsibility for the overall operation of the WWF or the pretreatment program. This authorization must be made in writing by the principal executive officer or ranking elected official, and submitted to the Department prior to or together with the report being submitted.

13. PROGRAM ASSIGNMENTS

14. PROGRAM ASSIGNMENTS

15. PROGRAM ASSIGNMENTS

16. Questions Contact: Samuel Jinkins Environmental Specialist III Domestic Wastewater Pretreatment Program sam.jinkins@dep.state.fl.us 850-245-8605