May 2002

1

Volume 7 Issue 2

PUBLISHED BY THE FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION

May 2002, Volume 7 Issue 2

byJohn Parnell

For those of you who couldn’t attend theFebruary 7-8 pretreatment coordinator’sworkshop hosted by Broward County, youmissed a terrific day and a half. I would liketo take this opportunity to thank the Countyfor the excellent venue and theirprofessionalism in organizing this workshop. Itwas amazing how all this came together soquickly. There were approximately 100attendees. The first half-day of the workshopincluded a discussion of Broward County’shauled waste program and a tour of thecounty’s septage receiving facility, followedby a presentation on the upcomingCapacity, Management, Operation andMaintenance (CMOM) requirements. Thenext day was dedicated to several topics tohelp pretreatment personnel become moreproficient in a number of areas. There werepresentations on use of the combinedwastestream and flow weighted averageformulae, compliance data tracking systems,developing local limits, and pretreatmentprogram significant noncompliance. I feltthis was one the best training workshops wehave had. The favorable feedback wereceived from the workshop evaluationsconfirmed my feeling.

By now most of the approved and pendingpretreatment programs, and a few “other”organizations, have received a copy of theState of Florida Guidance Manual forPretreatment Programs. If you did notreceive your copy at the February workshopor via mail, you will get it at your nextscheduled compliance inspection or audit.

(See Coordinator, page 3)

The next FIPA meeting will be held at theGainesville Regional Utilities Building, in, as youwould expect, Gainesville. Fred Williams(williamsfd@gru.com) has set the date for Friday,June 14, 2002 and the tentative meeting times will be9:00am till 3:00pm. The agenda is still in the processof being compiled. Be sure to mark your calendarsand plan to attend.

The association is at present arranging a partnershipwith the Florida Water Environment Association(FWEA) to sponsor a workshop at the end of theyear (probably October) to focus on the CentralizedWaste Treatment (CWT) category. This should be agreat opportunity to listen to some high powerpresentations on this subject so we will keep youinformed as the arrangements proceed. Finally, thenext FWPCOA short school will be in Cocoa Beachduring the week of August 12th to 16th, 2002. Wewill be offering the "C" class once again as we had avery good turnout (22 students) at the last shortschool in Ft. Pierce. Whether the "B" and "A" classesare held will depend on the number of students thatpre-register. We must have at least 8 students or theclass will probably be canceled. If you areconsidering either of these classes, get yourapplication in as early as possible so that we canreach our target of 8. Hope to see you in Gainesville.PS - FIPA is still accepting proposals of artwork for alogo of the organization by sending the designs tome via email at john.parnell@stpete.org

FLORIDA INDUSTRIAL PRETREATMENTASSOCIATION (FIPA)

A message from the President

May 2002

2

Volume 7 Issue 2

Regulatory DragnetU.S. EPA Headquarters Press Releases

CONNECTICUT COMPANY TO PAY $3 MILLION FOR WATER VIOLATIONSMacDermid Inc., a chemical manufacturer in Waterbury, Conn., pleaded guilty to four felony violations of the CleanWater Act and was sentenced on Nov. 28 to pay a $2 million fine and $1 million for supplemental environmentalprojects. MacDermid manufactures over 1,000 chemicals used for metal treating, plating and other purposes. The plantwastewater is required to be pretreated before being released into the Waterbury city sewer system, and the companyis required to submit to the Connecticut Department of Environmental Protection discharge monitoring reports (DMRs)concerning the level of chemicals contained in the treated wastewater it releases. For eight years or longer, MacDermidengaged in a set of unlawful practices, such as discarding wastewater samples that had high levels of pollutants andfailing to report analyses of such samples, which led to the falsification of its DMRs. As a result, wastewater withunacceptably high levels of copper and zinc was released into the Waterbury sewers. The release of wastewater withhigh levels of copper and zinc into sewer systems can cause damage to sewage treatment plant equipment and alsokill bacteria needed to digest and properly treat sewage at sewage treatment plants. The case was investigated byEPA's Criminal Investigation Division with the assistance of EPA's National Enforcement Investigations Center and wasprosecuted by the U.S. Attorney's Office in Bridgeport.

NEW HAMPSHIRE MEN CHARGED WITH ILLEGAL SEWAGE DISCHARGEThe indictment of Frederick B. Lawrence Jr., and Bradley G. Beaudoin, both of Troy, N.H., was announced on Nov. 30.Lawrence, chairman of the Troy Water and Sewer Commission, and Beaudoin, the superintendent of the Troy WasteWater Treatment Plant, were charged with installing an illegal pipe that allowed raw sewage and wastewater to leakinto the Ashuelot River. Such pollution can make the waters unsafe for drinking, recreation, fish and wildlife. Anindictment is merely an accusation and all defendants are presumed innocent unless or until proven guilty in a court oflaw. If convicted, each defendant faces a maximum sentence of up to three years in prison and/or a maximum fine ofup to $250,000. The case was investigated by EPA's Criminal Investigation Division with the assistance of EPA'sNational Enforcement Investigations Center and is being prosecuted by the U.S. Attorney's Office in Concord, N.H.

FORMER IDAHO REPAIR SHOP MANAGER PLEADS GUILTYKevin H. Jonely, former manager of Mac's Radiator & Repair Inc., Garden City, Idaho, pleaded guilty to violating theClean Water Act. In his plea, the defendant admitted that instead of hiring a licensed hazardous waste disposal firm toremove and dispose of lead-containing hazardous waste, he directed employees to help him break up the waste andflush it down the facility's sewer clean-out. He had been previously notified by a Garden City official that he did not havea Clean Water Act discharge permit to discharge the waste into the city sewer system, which was not designed to treathazardous waste. The waste contained approximately 4,400 parts per million lead. Lead is a toxic metal which can beharmful to fish and wildlife and can cause neurological and learning disorders in people. When sentenced, thedefendant faces a maximum sentence of up to five years in prison and/or a fine of up to $250,000. The case wasinvestigated by EPA's Criminal Investigation Division, the FBI, the Idaho State Police, the City of Boise and the City ofGarden City. It is being prosecuted by the U.S. Attorney's Office in Boise.

FORMER ILLINOIS REFINERY MANAGER CONVICTED OF WATER VIOLATIONSRonald Snook of Coal City, Ill., former Environmental Manager at Premcor's Blue Island Refinery, near Chicago, wasconvicted of conspiring to violate the Clean Water Act (CWA) and concealment of information from the MetropolitanWater Reclamation District of Greater Chicago (MWRD). Snook conspired with Premcor; Elva Carusiello, Premcor'sformer Environmental Engineer and Assistant Environmental Manager at Blue Island; and Environmental Monitoringand Technologies Inc. (EMT), of Morton Grove, Ill., a consultant to Premcor, to not report violations of the Blue IslandRefinery's CWA discharge permit. The permit limited the pH of the refinery's wastewater discharges and also limitedthe amount of fats, oils and grease that the refinery could release into sewers operated by the MWRD. The schemeinvolved failing to report tests that indicated the refinery was out of compliance with its discharge permit. The dischargeof wastewater with higher than permitted levels of pollutants and a high or low pH value, can harm sewage treatmentequipment and also harm fish and wildlife. In previous court actions in this case, Premcor paid a $2 million fine, EMTpaid a $50,000 fine and Carusiello pleaded guilty to a CWA violation. When sentenced, Snook faces a maximumsentence of up to five years in prison and/or a $250,000 fine on each count. The case was investigated by EPA'sCriminal Investigation Division with the assistance of EPA's National Enforcement Investigations Center, and is beingprosecuted by the U.S. Attorney's Office in Chicago.

May 2002

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Volume 7 Issue 2

This manual has been dubbed the FloridaGuidance Manual (FGM). The FGM wasdeveloped to assist developing, as well asalready approved pretreatment programs.The manual can be used as a guide tostart a new program or to enhance anexisting program. It has taken severalyears to develop the FGM and could nothave been possible without the assistanceof the following individuals:

Janet DeBiasio, City of St. PetersburgLaverne Hodge, Polk CountyTony Manello, City of Oldsmar (now withthe City of Dunedin)Jerome Mickens, Hillsborough CountyKelsi Oswald, Pinellas CountyRick Ruede, City of Lakeland

I would also like to acknowledge the workthat Chris Jensen of the Tallahassee DEPpretreatment staff has done on the FGM.When Chris joined our staff, I told him I hadone project that needed to be completedbefore he started on anything else. I toldhim he could learn about the pretreatmentprogram while he was completing thisassignment. I’m not sure Chris would havetaken this job if he really knew how manyproblems he would encounter as he pulledthis manual together. I won’t go into thegory details, but suffice it to say that hehad his hands full. To Chris’ credit, he wasable to complete the organization, editing,and reformatting of the FGM last July. Aftersome “fine tuning,” the FGM was sent tothe City of Hollywood for copying andbinding. The City of Hollywood providedthis service as an “in-kind” penalty projectin lieu of a monetary settlement of a DEPenforcement case. Many thanks to thecity for this creative way to resolve apenalty, at the same time helping thepretreatment program with a monumentaltask. Thanks to everyone who has helped

...Coordinator (Continued from page 1)

to make the FGM a useable product. Iencourage each of you to refer to the FGMoften as a source of guidance wheneveryou have a pretreatment related question.We have included copies of examples ofmany checklists, etc. that should be of use.If you find any errors or have suggestions foradditions or clarifications to the manual,please let us know. This manual will beperiodically updated to reflect changingregulations and/or policies. This projectwas funded, in part, with a grant from theUnited States Environmental ProtectionAgency.

I have been working with the Florida WaterEnvironment Association (FWEA) and theFlorida Industrial Pretreatment Association(FIPA) to help coordinate a specialtyworkshop on the permitting of CentralizedWaste Treatment (CWT) facilities. Theworkshop will include the industrial facilities,the pretreatment programs and, state andfederal regulators. At this point the workshopis targeted for October in the Orlando area.Please watch for future notification on thisactivity.

Speaking of the FWEA, I would like to extendmy congratulations to Burgess “Andy”Johnson on receiving the 2002 Albert B.Herndon Pretreatment Award at the 2002Florida Water Resources Conference inMarch. Andy has been involved with theCity of Orlando pretreatment program formany years and has contributed to thebetterment of the pretreatment programs inFlorida. He is very deserving of this award. Iunderstand that Andy is planning on retiringlater this year. When you see Andy,congratulate him and let him know that hispresence will be missed at our pretreatmentactivities.

On a final note, I hope you take time toread about the newest DEP pretreatment

(see Coordinator, page 6)

May 2002

4

Volume 7 Issue 2

Meet the Pretreatment Staff’s Newest Member

Marc Harris

I came to the Pretreatment Program from DEP’s Pollution PreventionProgram, where I assisted industry and local government staff with negotiatedpollution prevention (P2) projects that improved their facilities’operations and practices while reducing environmental impacts and insome cases regulatory reporting requirements.

Prior to the P2 Program, I was the Environmental Engineer and ISOCoordinator for Jack M. Berry, Inc., a citrus juice processing plant in

Southwest Florida, for two years. My responsibilities included development and implementation ofstandard operating procedures and work instructions from fruit receiving to fruit processing to juiceshipping to QA/QC to ancillary activities in order to meet the standards for ISO 9000 (quality) and ISO14000 (environmental) management systems. In addition, I supervised all three shifts of the QA/QClaboratory and was responsible for ensuring compliance with federal, state, and local rules and regulationsfor drinking water treatment, industrial wastewater discharge, air emissions, and hazardous wastemanagement.

As a result of working with all levels of staff on various types of projects, my background includesproduction scheduling, material handling, unit operations, inventory control and equipment maintenance-- just to name a few. I don’t hold a wastewater operator’s license of any level although I do have a ClassC drinking water operator’s license; most of you would probably argue that potable water is the source ofyour wastewater headaches. I look forward to assisting the pretreatment coordinators in continuing toimplement successful pretreatment programs.

F.I.P.A WorkshopJune 14, 2002

Sponsored by Gainesville Regional Utilities and the FDEPClear your calendars

More details with be forthcoming

May 2002

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Volume 7 Issue 2

MadisonMelbourneNew Smyrna BeachOldsmarOrmond BeachPalm BayPasco CountyPolk CountyPort OrangeRockledgeStuart

AuburndaleBartowCocoa BeachDaytona BeachFt. PierceGainesvilleHolly HillLake AlfredLake CityLakelandLoxahatchee ECD

As mentioned in the Coordinator’s Desk column, the pretreatment program assignments have beenreshuffled. Below is a list of active pretreatment programs and the assigned inspector.

OcalaPalm Beach CountyPanama CityPort St. JoeSanfordSeacoast Utilities AuthoritySeminole County

Bay CountyBoca RatonClay CountyDelandJEALeesburgMarion County

Marc Harris

Altamonte SpringsApopkaBroward CountyCasselberryCharlotte CountyClearwaterDavieEscambia CountyFt. LauderdaleFt. MyersFt. Walton Beach

Hillsborough CountyHollywoodLargoManatee CountyMiramarOrange CountyOrlandoPerryPinellas CountyPlant CityPlantation

Paul Brandl

Christopher Jensen

Reedy Creek Improvement Dist.St. PetersburgSunriseTampa

Tarpon SpringsTitusvilleVero BeachWinter Haven

South Central WWTPSt. AugustineSt. Johns CountyWest Palm BeachWildwood

May 2002

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Volume 7 Issue 2

engineer, Marc Harris (see Marc’s profile onpage 4). Marc replaced Sal Resurreccion,who left DEP for the Corp of Engineers inJacksonville. Marc started with us inFebruary and is a welcomed addition to thestaff. With Marc’s background in pollutionprevention (P2), he will be an asset to all ofus. Please feel free to contact Marc towelcome him and to pick his brain with P2questions. I have included a listingelsewhere in this newsletter of the newprogram assignments as a result of personnelchanges to my staff. Please take note ofyour DEP program engineer, it may havechanged.

Keep up the great work you are doing outthere. I’ll see you at your next inspection orFIPA workshop (June 14).

Bob HeilmanState of FloridaPretreatment Coordinator

...Coordinator(Continued from page 3)

Pretreatment Training Manualsfrom the

Florida Pretreatment CoordinatorsTraining Workshop

(February, 1999)

Blow-out Prices$15 each or $25 for the set

hurry...only a few left

Pretreatment ProgramFundamentals

&Industrial User

Classification and PermittingThese are excellent pretreatment Manuals

Produced by the EPAContact : Erik Melear @

(407) 246-2151or

erik.melear@ci.orlando.fl.us

Congratulations toMr. Mark MorrisCity of Vero Beach Pretreatment Program

Mr. Robert EvansCity of Plant City Pretreatment Program

Ms. Cheryl Staley-ArcherOrange County Pretreatment Program

Their facilities were nominated for potential receiptof a 2002 Clean Water Act Recognition Award. TheRecognition Awards acknowledge facilities thatdemonstrate a commitment to protecting andimproving the Nation's waters. Their facilities werenominated in the pretreatment category.

May 2002

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Volume 7 Issue 2

Do you or your industrial users need help?

It may be time to seek assistance from one of DEP’s Pollution Prevention (P2) Coordinators if you or yourstaff lack the time, resources or expertise to help industries with identifying pollution prevention solutionsto their discharge problems.

The P2 Coordinators are committed to helping Pretreatment Program Coordinators with implementingpollution prevention requirements by partnering with them on inspections and site visits at industries orthrough referrals.

For more information on the services that the P2 Coordinators can provide look at the map and talk to thePollution Prevention Coordinator in your area.

Northwest DistrictBrenda Leonard, P2 Coordinator(850) 595-8300 Ext. 1261

Jurisdiction: Bay, Calhoun, Escambia, Franklin,Gadsden, Gulf, Holmes, Jackson, Jefferson (westernhalf), Leon, Liberty, Okaloosa, Santa Rosa, Wakulla,Walton, & Washington

Southwest DistrictAl Gephart, P2 Coordinator(813) 744-6100 Ext. 372

Jurisdiction: Citrus, DeSoto, Hardee, Hernando,Hillsborough, Manatee, Pasco, Pinellas, Polk, Sarasota& Sumter

South DistrictLaura Comer, P2 Coordinator(239) 332-6975 Ext. 170

Jurisdiction: Charlotte, Collier, Glades, Hendry,Highlands, Lee & Monroe

Northeast DistrictChristopher Bodin, P2 Coordinator(904) 807-3300 Ext. 3370

Jurisdiction: Alachua, Baker, Bradford,Clay, Columbia,Dixie, Duval, Flagler, Gilchrist, Hamilton, Jefferson(eastern half), Lafayette, Levy, Madison, Nassau,Putnam, St. Johns, Suwannee, Taylor, & Union

Central DistrictDebby Valin, P2 Coordinator(407) 893-3323

Jurisdiction: Brevard, Indian River, Lake,Marion, Orange, Osceola, Seminole, Volusia

Southeast District Paul Thompson, P2 Coordinator(561) 681-6759

Jurisdiction: Broward, Dade, Martin,Okeechobee, Palm Beach, & St. Lucie

May 2002

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Volume 7 Issue 2

More Laboratory QualityAssurance

Best 2 out of 3 Proficiency TestsBy

Paul Salerno

Proficiency testing demonstrates a laboratory’sability to perform analysis on blind samplesusing a method producing enforceable results.In each pretreatment program the use of sampleanalysis to determine the compliance of theindustry is the basis of the enforcementresponse plan. How do you know thelaboratory you are using is still certified for thetests you require?

If the lab has been inspected by the FloridaDepartment of Health (FDOH) and has met therequirements, you should obtain a copy of itsNational Environmental Laboratory AccreditationConference (NELAC) accreditation certificate.The certificate should be placed in yourprogram file. To validate the lab’s proficiency,you will need to obtain a copy of the last threeproficiency studies performed. These studiesare required to be performed every six monthsby FDOH and there must be at least one monthbetween retesting studies and the scheduledstudies. Be sure to ask if there were other testsperformed to eliminate the use of the best threeinstead of the latest three. Discuss with yourlab notification procedures of any analytes thathave not passed the most recent two of threeproficiency tests.

You should generate a list of analytes you usefrom that lab in your program and match theresults to verify the lab has passed 2 of the last3 most recent proficiency tests of your usable

analytes. Should there be a failure (rated “NotAcceptable”) of an analyte in one of the threetests, there should be an accompanying letterto FDOH which addresses the deficiency andhow it will be, or has been corrected. Theperformance evaluation of “Acceptable” or“Check for Error” means the results are withinthe acceptable limits provided by the NELACaccredited sample provider.

If two of the last three proficiency tests of ananalyte have failed, the lab could bedecertified for that specific test. Contact thelab immediately and discuss how thecertification is being handled. Using a decertifiedanalyte in the compliance monitoring wherethe industry was found to be in violation maynot stand up in court. Should using adecertified analyte in monitoring occur,resample as soon as possible and use anotherlab that is certified in that particular analyte.

Working together with the lab director toprovide usable data for your program is anessential part of the compliance expectations.For further information the websitehttp://www.epa.gov/ttn/nelacprovides accredited proficiency test providersand links to proficiency testing requirements.

The author is the Pretreatment Coordinator and LabDirector for the City of Port Orange. In addition, he isthe current president of the Florida Society ofEnvironmental Analysts (FSEA).

May 2002

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Volume 7 Issue 2

1. A comprehensive and effectiveenforcement response plan mustadequately reflect the POTW’s primaryresponsibility to enforce all applicablepretreatment standards andrequirements.A. TrueB. False

2. POTW personnel can determine whethera discharge may generate gas/vapor-toxic conditions by comparing gas/vaportoxicity criteria to pollutantconcentrations in an industry’sdischarge.A. TrueB. False

3. Baseline monitoring reports are notrequired to contain any additionalinformation if the pretreatment standardsare not being met on a consistent basis.(Rule 62-625.(600)(1) Florida Administrative Code.)A. TrueB. False

4. If monitoring is necessary to measurecompliance with the 40 CFR 413 & 433TTO standards, the industrial useralways needs to analyze for all of thepollutants in the TTO list.A. TrueB. False

5. Which of the following types ofinformation should not be entered into afield notebook during inspections?A. names and titles/positions of all

facility personnel interacted withduring inspection

B. weather conditionsC. unusual conditions or problemsD. opinions or observations

regardless of support.

6. Material inventory is one of the generalelements of a ________ .A. self-monitoring reportB. discharge permitC. slug control planD. chain-of-custody form

7. Baseline monitoring reports for theCentralized Waste Treatment category(40CFR437) were/are due :

A. July 21, 2002B. July 21, 2001C. September 9, 2001D. December 15, 2003

8. Which of the following should not beused as criteria for determining a properresponse to a violation? (except whendeciding to pursue criminal prosecution)A. Magnitude of the violationB. knowledge, intent, or

negligenceC. Duration of the violationD. Effect of the violation on

the receiving water

9. What is the compliance date for Existing Sources in the Transportation Equipment Cleaning category ?

A. August 14, 2003B. August 14, 2002C. September 9, 2002D. July 21, 2002

Answers: 1-A; 2-A; 3-B; 4-B; 5-D; 6-C;7-B; 8-B; 9-A

May 2002

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Volume 7 Issue 2

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Pretreatment CommunicatorDomestic Wastewater Section2600 Blair Stone Road, MS 3540Tallahassee, Florida 32399-2400