1.2 Facility Classification & Operator in Direct Responsible Charge (ODRC)

1.2 Facility Classification & Operator in Direct Responsible Charge (ODRC)

[!IMPORTANT] The ODRC Mandate: Arizona Administrative Code (A.A.C.) Title 18, Chapter 5, Article 1 mandates that every regulated public water system and wastewater treatment facility must officially designate at least one Operator in Direct Responsible Charge (ODRC). The designated ODRC must hold an active ADEQ certification equal to or exceeding the facility's classification grade in the appropriate operational discipline.

Facility classification establishes a legal alignment between the engineering complexity of a utility and the qualifications of the personnel responsible for its operation. An underspecified or improperly supervised treatment facility poses immediate risks to public health and the environment. ADEQ's classification matrices evaluate treatment technologies, flow volumes, chemical hazards, and population served to assign each facility a Grade from 1 to 4.

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Facility Classification Matrices

Facility classification is governed by point-rating and threshold matrices set forth in A.A.C. Title 18, Chapter 5. The parameters differ across water treatment, water distribution, wastewater treatment, and wastewater collection.

1. Water Treatment Plants (WTP)

Water treatment classification is driven by the source water type (groundwater vs. surface water), raw water quality variability, design hydraulic capacity in Million Gallons per Day (MGD), and the complexity of chemical additions and physical separation processes.

2. Water Distribution Systems (WD)

Water distribution system classification focuses primarily on the population served, hydraulic pressure management, storage configurations, and booster pumping complexity.

3. Wastewater Treatment Plants (WWTP)

Wastewater facilities are classified based on influent raw wastewater strength, design hydraulic flow (MGD), receiving water sensitivity (APP groundwater recharge vs. AZPDES surface water discharge), and biological process complexity.

4. Wastewater Collection Systems (WWC)

Collection networks are classified by population served, pipeline diameters, flow capacity, and the presence of lift stations and force mains.

• Grade 1: Population ≤ 1,499; simple gravity systems with zero lift stations.
• Grade 2: Population 1,500 to 15,000; or gravity systems with 1 to 2 lift stations.
• Grade 3: Population 15,001 to 50,000; multiple regional lift stations, force mains, and inverted siphons.
• Grade 4: Population > 50,000; extensive metropolitan interceptors, complex telemetry, and high-head pumping stations.

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Designation & Responsibilities of the ODRC

The Operator in Direct Responsible Charge (ODRC) is the designated certified professional legally accountable for the daily operation of a facility. The facility owner must submit an official designation form to ADEQ naming the primary ODRC and any designated backups.

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|                         Core Responsibilities of the ODRC                         |
+-----------------------------------------------------------------------------------+
| 1. Daily Process Decisions     | Set chemical dosages, filter run cycles, return  |
|                                | sludge rates (RAS), and waste rates (WAS).       |
| 2. Regulatory Compliance       | Ensure strict adherence to NPDWRs, APP permits,  |
|                                | AZPDES effluent limits, and monitoring schedules.|
| 3. Operational Logbooks        | Maintain permanent, tamper-evident daily logs of |
|                                | all inspections, calibrations, and adjustments.  |
| 4. Emergency Management        | Lead response to line breaks, power outages,     |
|                                | chemical spills, and unpermitted discharges.     |
| 5. Staff Supervision           | Direct and supervise shift operators, mechanics, |
|                                | and laboratory personnel.                        |
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Shift & Substitute Operator Requirements

Operating utilities require 24/7 oversight or scheduled shift staffing. ADEQ rules delineate strict boundaries regarding who can make operational decisions:

• Shift Operators: Personnel on duty during specific operating shifts must be certified, but they may hold a certification grade lower than the facility classification, provided they execute standard operating procedures (SOPs) established by the ODRC.
• Substitute ODRC Provisions: When the primary ODRC is absent due to illness, vacation, or emergency, a designated substitute operator must assume responsibility.
  • An operator certified at or above the facility grade can serve as substitute indefinitely.
  • An operator certified one grade below the facility classification may serve as substitute for a temporary period not to exceed 30 consecutive calendar days, or no more than 60 cumulative calendar days in a single year.
  • The facility owner must formally notify ADEQ in writing if a lower-grade substitute serves as ODRC.

Daily Operational Logbook Protocols

Under A.A.C. Title 18, Chapter 5, Article 1, every regulated facility must maintain a contemporaneous, permanent daily operational logbook. The logbook serves as an official legal record of facility operations, compliance verifications, and physical inspections.

Formatting and Integrity Standards

1. Physical Logbooks: Must be hard-bound with pre-numbered pages. Spiral notebooks, loose-leaf binders, or loose paper sheets are strictly prohibited to prevent page substitution or destruction.
2. Electronic Logbooks: Permitted only if the software incorporates automated, tamper-evident security controls. These include unique cryptographic user credentials, time-stamped entries, and an immutable audit trail that tracks any amendments or edits without erasing the original text.
3. Correction Protocols: If an error is entered in a physical logbook, the operator must draw a single horizontal line through the incorrect entry, write the correct text adjacent to it, and sign or initial and date the correction. The use of opaque correction fluid (white-out), erasures, or blacking out text is a violation of recordkeeping rules.

Mandatory Daily Entries

The on-duty operator must record the following parameters daily:

• Date, shift times, and names/certification grades of all operators on duty.
• Water production and wastewater influent/effluent flow totals (in gallons or MGD).
• Chemical inventories, deliveries, and daily consumption (pounds fed, feed rates, dose calculations).
• Water quality test results (pH, free/total chlorine residual, turbidity, dissolved oxygen, MLSS).
• Equipment status changes (pumps started/stopped, filters washed, clarifier drive inspections).
• Calibration dates for process instrumentation (turbidimeters, pH probes, chlorine analyzers).
• System anomalies, emergency alarms, power outages, and corrective actions taken.
• Off-site regulatory sampling occurrences and chain-of-custody tracking numbers.

Record Retention & Inspection

Logbooks must be preserved on site and readily accessible for a minimum of 3 years from the date of the last entry (note that chemical and bacteriological compliance monitoring records must be retained for 5 to 10 years under SDWA and CWA mandates). During unannounced ADEQ sanitary surveys and compliance audits, the logbook is one of the primary documents reviewed by inspectors.

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Remote Monitoring & Unattended Facility Protocols

Across Arizona, many rural well sites, booster pumping stations, and automated package wastewater plants operate unattended. ADEQ permits unattended operation only under strict engineering and operational constraints:

• Automated SCADA Monitoring: Unattended facilities must be equipped with Supervisory Control and Data Acquisition (SCADA) systems that continuously monitor critical process setpoints.
• Fail-Safe Alarm Telemetry: The system must have automated dialer capabilities that broadcast critical alarms (loss of chlorine residual, high filter turbidity, high wet well level, low distribution pressure, power failure) to the on-call certified operator.
• Mandatory Physical Site Visits: Automated monitoring does not eliminate physical inspections. A certified operator must conduct scheduled physical site visits (typically daily or weekly, depending on facility grade and permit conditions) to verify equipment operation, log manual gauges, and conduct grab sampling.
• On-Call Response Time: The designated on-call operator must reside within a geographic radius enabling physical arrival at the facility within 1 to 2 hours of receiving an emergency alarm.

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Legal Liabilities & Disciplinary Proceedings under A.A.C. R18-5-115

Certified operators bear legal responsibility for public health and safety. Under A.A.C. R18-5-115, ADEQ possesses explicit statutory authority to investigate complaints, initiate administrative proceedings, and impose sanctions against certified individuals.

Grounds for Disciplinary Action

ADEQ may suspend, revoke, or refuse to renew an operator's certification upon finding that the operator has:

1. Fraud or Deceit: Obtained certification through fraudulent means, such as submitting false educational transcripts, forged experience verification letters, or cheating on examinations.
2. Gross Negligence: Demonstrated reckless disregard in the operation of a facility, leading to equipment destruction, extended distribution outages, or widespread contamination.
3. Incompetence: Consistently failed to exercise reasonable care or demonstrate technical competence in process control, chemical handling, or compliance reporting.
4. Willful Falsification: Deliberately falsified monitoring data, logbook entries, calibration records, or regulatory compliance submittals (such as Discharge Monitoring Reports).
5. Permit Non-Compliance: Willfully or repeatedly violated the provisions of the Safe Drinking Water Act, Aquifer Protection Permit, or AZPDES permit.

Administrative Hearings and Civil/Criminal Sanctions

Disciplinary proceedings adhere to Arizona administrative due process. ADEQ issues a formal Notice of Violation (NOV) or Notice of Intent to Revoke. The operator has the statutory right to request an evidentiary hearing before an independent Administrative Law Judge (ALJ) at the Arizona Office of Administrative Hearings (OAH). Following the hearing, the ALJ submits recommended findings to the ADEQ Director, who issues the final administrative order.

Beyond administrative certificate revocation, severe violations carry significant legal liability:

• Civil Penalties: Under A.R.S. Title 49, civil penalties of up to $25,000 per day per violation may be assessed against facilities and responsible corporate/individual entities.
• Criminal Prosecution: Knowing or intentional falsification of environmental compliance documents is classified as a Class 5 felony under Arizona Revised Statutes, exposing the individual to potential state imprisonment and criminal fines.