The Wastewater Operator of Record

July 22, 2016

Industries should consider the status of this operator because it must be known and accurate to maintain compliance with discharge requirements.

This column examines the wastewater operator of record. This is important because, at all times, wastewater treatment plant facilities have a required process that begins with an environmental regulator issuing a permit to construct a facility. After the construction is complete, the facility is determined to satisfy the requirements of the construction, and the environmental regulator will issue a permit to operate. The wastewater operator of record is responsible for the operation, maintenance and recordkeeping necessary to ensure the plant meets all the requirements of the environmental and operating permits.

The limits/specifications for the discharge are included when the operating permit is issued. This includes the quantity and the quality of the discharge and the required license level of the wastewater treatment plant operator of record. The person in this role may or may not be an operator on site at the wastewater treatment facility, but the requirements for this role must be met and the experience level must satisfy the discharge permit specifications.


In this section, I will explore examples in which these requirements may have been deficient because, for different reasons, the operator of record was unable to serve in the role.

Lapsed license

At one industrial wastewater treatment facility, the operator of record allowed his license to lapse or become inactive, and he no longer had a valid active wastewater operator’s license. Unfortunately, this was brought to the attention of the industry contact from the regulator. The industry contact was reminded that the discharge permit required the company to have an active operator of record.

Through a series of searches and interviews with the industry professional, I was selected to be the operator of record to satisfy the discharge permit requirements.

Contract operator

In another example, a company used a contractor as the operator of record. Unfortunately, this individual was in an automobile accident and was unable to continue to serve in that role. Because of an earlier contact, the company contacted me and explained the current situation. At this point I became their operator of record to satisfy the requirements.

Employee turnover

Other situations involved me temporarily serving as the operator of record. One instance occurred when an employee who was operator of record resigned from the company and no one filled the role. The company manager and I connected, and the company utilized me as its operator of record.

In another situation, an employee retired and the industry had no operator back up with the required license level. Through internet searches, the industry professional contacted me, and I was able to fill that role for them.

At another facility, the company felt it could do better with a different person filling the role. Because I was the trainer of their employees and ultimately had an opportunity to deliver training on site too, I was brought in as the operator of record for that facility.

Multiple personnel with the correct license level

In addition to satisfying the operator of record requirements, facilities should have multiple individuals with the credentials required for an operator of record to serve as a backup if needed. I have actually assisted with situations in which the operator of record for multiple industries was the only operator and personal issues forced the operator to be unable to work. Of course, the companies were in violation with their discharge permits because of this.

Another important consideration is to ensure that the individuals operating the wastewater treatment plant are either licensed operators at any level or designated by the licensing authority as an operator in training who operates under the supervision of a licensed operator. This setup will increase the confidence level that the facility will be operated according to the required procedures.

When seeking to hire operators and operators of record, individuals who generate wastewater in the production areas of the facility are good candidates to be licensed operators. Also, those who maintain and repair wastewater equipment also have potential to be licensed wastewater operators.

Examine the results

The status of wastewater operators and wastewater operators of record must be known and accurate to maintain compliance with discharge requirements. As a facility manager examines the requirements, understand that wastewater operators’ active statuses are contingent upon continuing education. The status of the operators, operator of record and any backup operators must continue to train to prevent a license lapse.

In addition, having a wastewater operator on site at all times is a good idea. This on-site operator does not need to be at the level of an operator of record, but he or she must understand the requirements of the treatment and how to satisfy the wastewater discharge permit parameters.

Following these procedures and suggestions can help ensure compliance.

Known in the industry as "Wastewater Dan," Dan Theobald, 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.

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