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.
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.
|
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.
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).
|