Florida Department of Environmental Protection FDEP State Pretreatment Update Industrial Pretreatment Program Sam Jinkins, Pretreatment Specialist Overview • Introduction - Ms. Randi Peddie • Inspections - FOG and SSOs • Rule Revision - Program document updates • Annual Reports/DMR Requirements • Program Assignments Introduction • New Addition to FDEP’s industrial pretreatment Staff - Ms. Randi Peddie 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. 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 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 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 Chapter 62-625, F.A.C. Revisions • Common Problems • Multiple Changes to SUO due to permit renewal that includes a local limit reevaluation • 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 Where should BMPs go in SUOs? Required and Optional Sections 2007 EPA Model SUO Reference Florida Administrative Code Reference Definition (required) 1.4 E 62-625.200(2) Local Limits (optional) 2.4 C. 62-625.400(3)(d) Application Contents (required) 4.5 A.(7)d. 62-625.600(1)(e)2. Permit Contents (required) 5.2 A.(3) 62-625.500(2)(a)2.c. Reporting (required) 6.4 A. 62-625.600(4)(a) and 62625.600 (7)(a) Record Keeping (required) 6.13 62-625.600(14) Significant Noncompliance (required) 9 H. 62-625.500(2)(b)8.h. 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 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 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. PROGRAM ASSIGNMENTS John Palenchar (850) 245-7566 Altamonte Springs, City of Apopka, City of Auburndale, City of Clearwater, City of Hillsborough County Lakeland, City of Largo, City of Oldsmar, City of Pasco County Pinellas County Plant City, City of Sanford, City of Seminole County St. Petersburg, City of Tampa, City of Tarpon Springs, City of Winter Haven, City of PROGRAM ASSIGNMENTS Randi Peddie (850) 245-8607 Broward County Clay County Daytona Beach, City of Deland, City of Ft. Pierce, City of Gainesville, City of JEA (Jacksonville, City of) Lake City, City of Loxahatchee ECD Martin County Orange County Orlando, City of Ormond Beach, City of Palm Beach County Port Orange, City of Reedy Creek Improvement Dist Seacoast Utilities Authority South Central WWTP St. Augustine, City of St. Johns County Tallahassee, City of West Palm Beach, City of Winter Garden, City of PROGRAM ASSIGNMENTS Sam Jinkins (850) 245-8609 Bay County Cocoa Beach, City of Collier County Davie, Town of Escambia County Ft. Lauderdale, City of Ft. Myers, City of Hollywood, City of Indian River County Lee County Leesburg, City of Manatee County Marion County Melbourne, City of Miramar, City of Ocala, City of Okaloosa County Palm Bay, City of Panama City, City of Perry, City of Plantation, City of Port St. Joe, City of Rockledge, City of Titusville, City of Vero Beach, City of Wildwood, City of Questions Contact: Samuel Jinkins Environmental Specialist III Domestic Wastewater Pretreatment Program sam.jinkins@dep.state.fl.us 850-245-8605