Not long ago, I served as the contract wastewater operator of record at an industrial company. The company’s environmental health and safety (EHS) manager and I agreed to share responsibilities. I would oversee the wastewater operation to satisfy the wastewater discharge permit for the industrial company primary contact for the regulator. The EHS manager would maintain all the records pertaining to correspondence between the regulator and the industrial company.
It was all clearly defined, yet one day, I found out that the EHS manager was no longer an employee of the industrial company. I accepted additional responsibilities for all the documentation requirements pertaining to the discharge permit.
The EHS manager had told me about his firm grasp on all relevant documentation, and we had reviewed documentation previously filed. However, following his departure when I searched for the documentation, I found to my dismay that record retention had in fact been virtually non-existent in subsequent years. In fact, we were at the least technically in violation of the three-year minimum record retention requirement.
Explore an example
Now the real work began. I had to first find out what files the former employee had retained and what was missing, and I needed to gather all required information and file it in a binder so it could later be retrieved for evaluation.
The only documentation we found in the office was a single 16-year-old obsolete discharge permit. When we looked on the former employee’s computer, we only located some of the required documentation. It was an even more pain-staking process to determine what documentation was missing.
I contacted the regulator to ask if it would share with me any correspondence it had exchanged with the former employee because I had to document a minimum of three-year records retention.
This former employee had worked for the company more than three years, so the correspondence with the regulator ensured that the three-year period was covered. With the information the former employee would have received, I was able to identify the documentation that I had prepared and which should have been retained by the former employee.
This was very time-consuming and painstaking because once the information was gathered, a filing system needed to be established of the past three years of records.
Examine the result
The records I compiled were divided into a main discharge permit binder and a supporting discharge permit binder. Note that in industrial wastewater, regulators still like to see hard copies of documents filed in binders. However, industrial companies also often file the documents in a digital format as well.
The main discharge permit binder held the current discharge permit and the old discharge permit that was superseded during the current year of this project. The history included an application that was developed into a draft. Preceding that was an older discharge permit.
The binder also contained the monthly self-monitoring reports. We gathered four years of data including the laboratory analysis report and statistics on monthly flow discharged on a daily basis. Bundling this information with the signatures certification statement and the regulator’s status reporting provided what was needed for the monthly documentation.
We did this for four years and added sections in the binder for any notices of violation, flow meter calibration letters, annual inspections, location of records and authorize signatory. A supporting binder also contained the monthly laboratory analysis report in detail for each month.
The regulator’s next annual inspection was a proverbial "piece of cake" because the records were so complete and the data so easy for the representative to find tha the rest of the inspection went really smoothly.
Finally, another customer interacting with the same regulator had some useful information contained in its binder, and we included the same type information in their data collection and record retention efforts at the first company.
Ultimately, complete retrievable documentation of records satisfies the discharge permit and enhances satisfactory regulatory annual inspections.
Editor’s Note: This article on discharge permit compliance is part of a series from Wastewater Dan that identifies procedures used to troubleshoot wastewater treatment.
Known in the industry as "Wastewater Dan," Dan Theobold, proprietor of Environmental Services, is a professional wastewater and safety consultant/trainer. He has more than 24 years of hands-on industry experience operating many variants of wastewater treatment processing units and is anxious to share his knowledge with others.
