17.3 Administrative Procedures: SOPs, O&M Reports, Discharge Monitoring Reports & Recordkeeping

17.3 Administrative Procedures: SOPs, O&M Reports, Discharge Monitoring Reports & Recordkeeping

Exam Focus: Six of the line items in the Security, Safety, and Administrative Procedures content area are administrative rather than safety-related: complete O&M reports, complete required regulatory reports, ensure compliance with applicable regulations, respond to customer service requests and complaints, adhere to SOPs, and establish and/or update SOPs. Candidates who study only safety are leaving marks on the table.

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1. Standard Operating Procedures

A standard operating procedure (SOP) is a written, step-by-step description of how a specific task is performed at this plant. Its purpose is consistency: the same task performed the same way by every operator on every shift, on nights and weekends, by the new hire and by the twenty-year veteran.

A usable SOP contains:

• Purpose and scope
• Safety requirements and required PPE up front, before the steps
• Equipment, materials, and reagents needed
• Numbered step-by-step procedure
• Acceptance criteria — what a correct result looks like
• Troubleshooting for the common failure modes
• Records to be completed
• Revision number, effective date, author, and approver

Maintaining SOPs is itself a named exam topic. SOPs must be reviewed on a defined cycle and updated whenever equipment changes, a chemical changes, an analytical method is revised, a regulation changes, or an incident reveals a gap. Superseded versions must be removed from circulation so nobody works from an obsolete copy, and training records should show who has been trained on the current revision.

2. Operation and Maintenance Reports

Write logs so they are useful to someone else. "Adjusted RAS" is nearly worthless. "Increased RAS from 2.1 to 2.6 MGD at 1420 in response to clarifier blanket rising to 3.5 ft; blanket at 2.1 ft by 1800" tells the next operator what happened, why, and whether it worked.

Preventive versus corrective maintenance is a distinction worth stating plainly: preventive maintenance is scheduled work performed to prevent failure, corrective maintenance is repair after failure, and a plant whose maintenance is overwhelmingly corrective is a plant operating in a permanent state of surprise. Run hours and equipment history are what allow a shift from one to the other.

3. The Discharge Monitoring Report

The Discharge Monitoring Report (DMR) is the periodic report on which a permittee reports its own monitoring results against its permit limits.

• It is self-monitoring: the permittee collects, analyzes, and reports its own data.
• It is certified by a responsible official, who signs a statement affirming that the information was gathered under their direction and is, to the best of their knowledge, true, accurate, and complete, and acknowledging that there are significant penalties for submitting false information.
• Most permittees now submit electronically through the NPDES electronic reporting system rather than on paper.
• The DMR reports what the permit requires at the frequency the permit requires — missing a required sample is itself a violation, separate from any limit exceedance.

Averaging Conventions

Permits use specific averaging periods, and using the wrong one produces a wrong report:

4. Recordkeeping and Retention

• NPDES records must be retained for at least three years from the date of the sample, measurement, report, or application. This includes all monitoring information: the date, exact place, and time of sampling; who performed the sampling; the analytical dates and methods; who performed the analyses; and the results — plus calibration and maintenance records and original strip chart or instrument recordings. The regulatory authority may extend the retention period.
• Biosolids records under 40 CFR Part 503 are retained for five years, covering pathogen and vector attraction reduction compliance, metals concentrations, and land application site and loading data (Section 6.4).
• Safety records carry their own retention requirements — training, confined space entry permits, exposure monitoring, and hearing conservation audiometric records.
• Records must be legible, complete, and retrievable. A record that cannot be produced during an inspection is functionally a record that does not exist.

Never falsify, and never quietly omit. Knowingly falsifying or tampering with monitoring data or reports under the Clean Water Act is a criminal offense, not merely an administrative one, and it carries penalties for the individual as well as the utility. If a sample was missed, record that it was missed and why. If a result is invalid because an instrument was out of calibration, report it as invalid with the explanation attached. If a limit was exceeded, report the exceedance and the corrective action. Every one of those is a manageable problem; altering a record is a career-ending one.

5. Responding to Customer Service Requests and Complaints

Named directly in the Need-to-Know Criteria, and genuinely part of an operator's job.

The professional standard is the same in every case: log it, investigate it, act on it, close the loop with the person who called, and trend the complaints. A cluster of odor complaints from one neighborhood over several weeks is process information, not just a nuisance.

6. Assisting in Equipment Selection

The criteria list "Assist in the selection of equipment for use in wastewater processing," because operators hold information engineers do not: which pump models have actually survived in this service, which valve packs with rags, where access for maintenance is impossible, which instrument needs cleaning twice a week. Useful operator input covers maintainability and access, parts availability and standardization with existing units, energy consumption, reliability history at this plant, safety of routine servicing, and the training required — not just purchase price.