DEP's Northwest District Clarifier Wastewater Newsletter

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May 2020

Our Offices are Currently Closed to the Public, but We are Working and Available to Assist You!

Although our offices are currently closed to the public, our team is available to assist you and continues to perform compliance assurance functions including inspections. We will make every effort to comply with social distancing protocols and ask that you do the same. We will make every effort to minimize contact and will use masks when social distancing is difficult to maintain. If you have any questions or concerns, please let us know.

Guidance for Wastewater Workers

As coronavirus 2019 (COVID-19) gains attention worldwide, industry groups are releasing information and advice for water and wastewater professionals.

The Occupational Safety and Health Administration (OSHA) recently released guidance for wastewater workers, reporting that coronaviruses are vulnerable to the same disinfection techniques used currently in the health care sector. “Current disinfection conditions in wastewater treatment facilities is expected to be sufficient,” according to OSHA. “This includes conditions for practices such as oxidation with hypochlorite (i.e., chlorine bleach) and peracetic acid, as well as inactivation through the use of ultraviolet irradiation.”

OSHA also reports that, currently, there isn’t evidence to suggest wastewater treatment plant operators and sewer workers need to enact additional protections specific to COVID-19, but added that “wastewater treatment plant operations should ensure workers follow routine practices to prevent exposure to wastewater, including using the engineering and administrative controls, safe work practices, and PPE normally required for work tasks when handling untreated wastewater."

wash hands

Water Assistance Tracking and Emergency Response (WATER) is Live!

WATER

DEP launched the new online system WATER (Water Assistance Tracking and Emergency Response) on April 13, 2020. This new system combines DEP's former StormTracker website and Florida Water/Wastewater Agency Response Network (FlaWARN) event tracker. WATER will ensure that needs of individual facilities are met as quickly and efficiently as possible.

The overall solution was to create one source for all water and wastewater facilities to report event-related status, and to submit needs and request resources. This new system is designed for all hazard types including both natural hazards (tropical storms, hurricanes, floods, etc.) and malevolent acts (contamination of finished water or source water, assault, cyber-attack, etc.). You can access the website at http://www.flwatertracker.com/.

Now is the Time to Update Your Wastewater Treatment Facility Emergency Operation Plans

Wastewater treatment facility permittees and operators are reminded that with hurricane season approaching (June 1), this is a good time to make sure your WWTP Emergency Operation Plan (EOP) is up to date. The EOP addresses larger events such as hurricanes, flooding or significant power outages. The EOP should be designed to build on the Sewer Overflow Response Plan (SORP) and include the following components:

  1. Numbers and type of portable or fixed generators, bypass pumps, vacuum trucks, transport vehicles, personnel, and quantities of fuel to be kept in readiness for emergencies, and how items will be mobilized and deployed to keep pump stations and wastewater treatment and disposal operating during a significant power outage event.
  2. What outside resources, such as contractors, mutual aid agreements or FlaWARN, may be called upon when needed, how the request for assistance is handled, what documentation is necessary as work proceeds, and how the outside assistance will be supervised, accounted for, and coordinated with respondent’s own equipment and personnel.
  3. A public education campaign with three components:

    a. Outreach to customers via social media and other means prior to hurricane season addressing sanitary sewer overflow prevention through maintenance of service connections and grease traps, not opening cleanouts or manholes, and preventing blockages.
    b. Outreach as a predicted event approaches (e.g., hurricane) addressing what customers should do or should avoid to prevent or be prepared for sanitary sewer overflows, and how customers can get information regarding their system before the storm.
    c. Outreach after the event addressing how to deal with backups and floodwaters, proper cleanup, health precautions, and how to get information about the sewer system’s status or report problems.

Upset Provisions in General Conditions for All Permits

What is an upset?
As defined by 62-625.200(28) F.A.C., an upset is an exceptional incident in which there is unintentional and temporary noncompliance with categorical pretreatment standards beyond the reasonable control of the industrial user. This does not include noncompliance caused by operational error, improperly designed treatment facilities or lack of preventative maintenance.

What information should facilities provide to the department to demonstrate noncompliance was due to an upset?
In the case that an upset occurred at a facility that was caused by factors beyond the control of the facility’s permitted operation, evidence may be provided to the Department to establish a defense of the upset. All evidence submitted must be properly signed (operating logs for example), recorded during or shortly after the upset, and considered relevant to the event. 

Evidence provided must demonstrate the following criteria:

  -  A specific cause for the upset can be identified.
  -  The facility was being properly operated during
     the time the upset occurred. This includes
     proper staffing and proper operating logs that
     reflect the process of identifying and
     remediating the upset.
  -  Notice of the upset was provided to the
     department.
  -  Actions were taken to correct the upset in a
     timely manner that did not require reduction of
     the permitted activity.

DEP issues Emergency Final Order in Response to COVID-19

While the department expects facilities to make every effort to comply with their environmental compliance obligations, we recognize that COVID-19 may cause disruption in supply chains and the labor force. In recognition that this can impact the ability of regulated entities to meet certain regulatory deadlines, DEP has issued Emergency Final Order (EFO) April 1, 2020.

The EFO states that the department will continue to carry out all inspections, testing, data and file reviews, and other compliance verification activities to ensure full compliance with regulatory and pollution prevention requirements, including the pollution notification requirement under Section 403.077, Florida Statutes.

Paragraph three of the EFO allows an extension of time for permitting and compliance deadlines if delays are related to COVID-19. Facilities impacted by COVID-19 should consult with the district office concerning any delays. 

EzDMR Codes for COVID-19 Related Delays

The department has developed a new reporting code to use in EzDMR that should be used if a facility is missing data when it is due for reasons specifically related to the current COVID-19 pandemic. 

The facility should use the comment field to enter a comment “COVID-19,” and include sufficient justification as to how the impacts from COVID-19 resulted in missing data. This code should be used only for data collected in March 2020 and beyond in accordance with current and emerging guidance. While facilities can use this code for missing data that could not be monitored or sampled due to reasons specifically related to COVID-19, facilities should continue to report all other data as required.

Pandemic Resilience Plan

Wastewater and drinking water systems should create pandemic resilience plans to add to their Emergency Response Plans. Please see this EPA resource for helpful tools and checklists.

Do You Need Masks for Critical Operations Employees?

The Florida Rural Water Association (FRWA) has let us know that they have a supply of KN 95 and three  part fiber masks to sell at cost to water utilities in Florida. To better serve all of their members, they are limiting the size of each order. Click here for the order form. Complete the form and email to Admin@frwa.net or fax to 850-893-4581. Please contact FRWA at 800-872-8207 with any questions.

FRWA has developed a webpage dedicated to keeping water and wastewater systems informed on the latest developments concerning COVID-19.

Electronic Sanitary Sewer Overflow Reporting Tool

SSO

DEP has made sanitary sewer overflow (SSO) reporting more user-friendly for regulated facilities. The submission is available in the DEP Business Portal , and instructions on reporting through the Business Portal are available at DEP Business Portal Sanitary Sewer Overflow Reporting Tool.

Users can choose to have the system automatically use the entered information to generate a Public Notice of Pollution. However, reporting the spill information through the DEP Business Portal does not alleviate the requirement of reporting the spill to the State Watch Office or the district office or delegated local program, if it meets the conditions in the reminder below.

Please contact the Northwest District Wastewater Compliance Section at 850-595-8300 with any reporting questions. For technical assistance, please call DEP's Office of Technology and Information Services at 850-245-7555.

Reminder:
Wastewater incidents, which include SSOs, can pose a threat to the environment and public health. Immediate notification and appropriate response are essential factors for minimizing the impact from wastewater incidents. SSOs, which are of 1,000 gallons or greater or which may threaten the environment or public health, are required to be reported as soon as practical, but no later than 24 hours after discovery by a utility to DEP through a toll-free, 24-hour hotline known as the State Watch Office at 1-800-320-0519 (Reference Chapters 62-604 and 62-620, F.A.C.). The public also is encouraged to report any suspected wastewater incidents to the toll-free number. Please note that a utility that experiences an SSO less than 1,000 gallons is only required to report such incident to DEP by notifying their appropriate district office.

helpful links

- EzDMR
Information Portal
Northwest District Website
Northwest District Contacts
Notification/Application for Constructing a Domestic Wastewater Collection/Transmission System (Notification/Application)
Operator Certification
Preventing SSOs Fact Sheet
- Quality Assurance SOPs
Request for Approval to Place a Domestic Wastewater Collection/Transmission System into Operation (clearance)
- SSO Fact Sheet 
- Wastewater Rules

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