Oh those pesky permits: Three things every WWTP owner should do right now!

July 18th, 2011     1 Comment »


It happens a lot, two or three times a week perhaps, that we meet a potential new client and find that not only have they never seen their permit, they aren’t getting the services their permit requires.  We commonly come across companies that are receiving one visit a week when their permit says they should have three.  Or three visits per week when they should have five, and often they had no idea that the reduced visits were a violation.  Occasionally, we meet people that have received a fixed price for services, a flat fee for “everything”, only it has never really been made clear what “everything” is or if it is even “everything”.  $200.00 a month for operations may seem like a great deal, but if you are in violation of your permit, it isn’t a deal.  It’s a waste.  You have just paid someone to get you into trouble.

So what is a lay person to do?  How can you know if you are getting a good deal or not, or if they are doing the work or not?  Here are a three easy ways an owner of a wastewater (or water) treatment plant can check to see how well their operator is doing.

·         Have a copy of your NPDES permit.  Your permit is available to anyone and everyone on the EPA website.  It’s yours and you should have it.  It details how many hours of operation your plant requires, as well as how often you should be sampled and from where as well as the analytical requirements for those samples. 

·         Do the math.  If your permit requirements say that your operator is supposed to be on site three days a week, and you’re being charged $200.00 per month for inspections, that means they are receiving only $16.66 an hour to fulfill the requirements of your permit.  If that seems reasonable to you, that $16.66 an hour can cover the cost of an employee, all the overhead (insurance, workers comp, vehicle gasoline, maintenance, etc.) of that employee plus the cost of the internal processes of receiving your inspections to be compiled into report format for the EPA and make a profit (it is a business after all), then you can probably stop reading right here.  Because you are getting what you pay for.  For everyone else, red flags start waving. Some companies have a business model that requires them to not do the work.

·         Check your log book.  And perhaps I should start by saying, you should have a log book and not having one is a violation.  The log book is crucial, and by the way, it’s your property.  The EPA requires every plant to have a log book on-site.  In your operator’s car or office does not count either, and they know that.  Every inspection, every bit of maintenance, should be dated and recorded in that book, and it is the first thing the EPA asks for when doing an inspection.   If your log book is missing entries or doesn’t have enough entries, that could be a giveaway that something is wrong.  Don’t have a book at all?  Hmmm, now why wouldn’t your operator want you to know how much time he or she spends at your plant?  Curious.

Obviously, you hired an outsider to take care of this because you didn’t want to be your own expert.  And really, you don’t need to be.  But be an informed consumer, and if the person working for you seems hesitant for you to be informed, it might be time to find a new operator.

One Response to “Oh those pesky permits: Three things every WWTP owner should do right now!”

  1. Do you know Elias Feghali or The Harv? They had a message on their BBS telling me to check your guy’s web site out.

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