Welcome to the first edition of The Mix! Our goal is to pass along information that supports your efforts to maintain your facility in compliance with Florida's industrial wastewater, fuel tank and air rules and regulations. We hope you find the information in this and future editions useful. We welcome your comments and ideas.

What to Expect During an Industrial Wastewater Inspection

DEP is required to conduct industrial wastewater inspections of Concrete Batch Plants (CBP) every three years. However, inspections can also be initiated by a customer complaint or a compliance-assistance visit requested by the facility. During these visits, inspectors evaluate compliance with permit requirements, including record keeping, operation and maintenance and a facility site review. Below are records an inspector will ask for and will want to review during an inspection of your facility. At the completion of the inspection, the inspector will review findings with you and answer questions you may have.

The following records must be kept on-site:

• Industrial Wastewater Generic Permit and associated documentation (completed NOI, Engineering Report and as-built drawings);
• Wastewater Stormwater Management Plan (WSMP) including Best Management Practices (BMP);
• Facility inspection logs, hauling records of reclaimed solids, maintenance and employee training logs;
• Waste oil/filters and recycled wash water hauling records (if applicable); and
• MSDS for chemicals on-site.

Walk-through of the plant will check to make sure:

• There are no unauthorized discharges off-site;
• Wastewater is not escaping containment system(s) and/or pond(s);
• There are no unauthorized diversions of wastewater (i.e. routing type II wastewater to a type I system);
• Type I wastewater is properly conveyed through the sediment trap(s);
• Proper maintenance and use of all containment systems;
• Comparison of submitted drawings to what is constructed; and 
• Proper use of reuse water.

 Common deficiencies found during inspections include:

• Failure to have a copy of the permit and/or engineering drawings on-site;
• Failure to develop WSMP as required; or, if developed, WSMP was not on-site;
• Failure to implement WSMP;
• Failure to conduct inspections required by the WSMP; if conducted, failure to properly document them (complete checklists);
• Improper handling of truck washout water and other wastewaters;
• Improper dewatering of Type II solids; and
• Type I ponds, Type II ponds, and sediment traps not being properly maintained and managed.

Does Your Facility Have Fuel Storage?

The fuel storage tank at your facility might be subject to Florida’s storage tank regulations. Aboveground tanks with a holding capacity of more than 550 gallons that contain regulated substances must be registered with the Department, and comply with registration, operational, maintenance, and financial responsibility requirements. Vehicular fuel – including diesel and gasoline – used to power on-site or off-site vehicles is a regulated substance. 

Facilities with regulated tanks that have been registered with the department and have an assigned facility ID number will be inspected at least once every two years.  Florida has delegated storage tank compliance inspection authority to local county programs, typically Department of Health offices. If you are registered, you will receive a call from an inspector who will work with you to schedule an inspection in five to seven days.  

If you have a storage tank at your facility that you suspect is regulated, please contact Mark Gillman, Environmental Consultant, at 850-595-0586. He will help you determine if your tank is regulated, and will help you meet Florida’s storage tank regulations.

Northwest District's Wastewater Permitting Program Staff

The Northwest District's Wastewater Permitting Program staff has a vast knowledge base. With more than 20 years of service to the state, Bill Evans, P.E. serves as supervisor. Bill Armstrong, P.E. and David Morres, P.E. offer experience and dedication with more than 10 years of service to the state. Jim Billizon, P.G. provides expert analysis for all groundwater-related wastewater permitting projects. Linda Bauer recently joined the wastewater permitting team from the waste cleanup section, and Rich Boelens moved from the stormwater permitting section to wastewater permitting. Katie Ates, E.I.T. joined DEP after graduating from the University of Florida. Our permitting team is always willing to assist you with any permitting questions.

Attendees of the 2014 Concrete Batch Plant Workshop in Pensacola.

Developing Your WSMP and BMPs

One of the required components of a facility's General Permit is the Wastewater and Stormwater Management Plan (WSMP), which addresses the CBP facility’s Stormwater Management System. Lacking a WSMP plan is one of the more common deficiencies noted during inspections. The following guide below should help a facility develop, or enhance, an existing WSMP. Please note that this is an informational guide and the facility should always consult the permit for specifics.

The WSMP consists of two primary elements: Best Management Practices (BMP) and Stormwater Pollution Prevention (SWPP).

The BMP Element

The BMP element should address the specific operation and maintenance requirements to ensure continued proper functioning of all on-site pollution control facilities and specific procedures for long-term operation of the Type I and Type II system components. These include but are not limited to:

• Specific BMPs for beneficial use/recycling of Type I and Type II wastewater such as: cleaning out concrete truck mixer drums, the manufacture of concrete and sprinkling on aggregate piles.
• Specific BMPs for the proper on-site handling of any sludge/solids removed from the Type I and Type II systems.

 The SWPP Element

This component shall identify potential sources of pollution affecting the quality of stormwater discharges associated with industrial activity from the facility and the plan shall implement practices to reduce the pollutants in stormwater discharges to assure compliance with the permit. The permittee can amend the SWPP element as necessary. The plan will include: 

• Pollution Prevention Team: Specific individual(s) within the facility organization responsible for developing and implementing the plan.
• Description of Potential Pollutant Sources: Describes potential sources that could add significant amounts of pollutants to stormwater discharges.
• Good Housekeeping Requirements: Indicates the frequency of sweeping or other measures to prevent the exposure of fine granular solids to stormwater.
• Preventative Maintenance: Develop a program that involves timely inspections, maintenance, and operation of stormwater management devices and existing dust collection systems.
• Spill Response: Procedures identifying proper equipment for cleaning up spills.
• Inspection Frequency: Based on the level of industrial activity at the facility, but shall be at least once per month while in operation. 
• Employee Training: Employee training programs shall address topics such as spill response, good housekeeping, truck washout procedures, equipment wash-down procedures and material management practices.
• Record Keeping and Internal Reporting Procedures: Describe how inspections, maintenance activities and incidents shall be documented and kept.
• Sediment and Erosion Control: Areas that have a high potential for significant soil erosion shall be identified and steps taken to address them.

Always remember that the plan shall be signed in accordance with Rule 62-620.305, F.A.C. and the plan shall be maintained on-site and made available to DEP inspection personnel. 

Friendly Air Program Reminders

Get your annual testing requirements taken care of early by scheduling your Method 9 Visible Emission tests now! Then you don’t have to worry about it again until 2017! Don't forget to send your notification 15 days in advance to NWDAIR@dep.state.fl.us.

Now is also a great time to check your air permit expiration date. You don’t want to miss the renewal registration deadline! Not sure when your permit expires? You can find the information you need online at AirInfo, our new public access database. Search using your permit number for details.

Time for renewal? Now you can register online with no paperwork hassle. Check out our Air General Permits Electronic Registration Submittal (AGPERS).