Government/Utility

LCG provides assistance to government and utility customers for water, wastewater, and groundwater project and program compliance needs. LCG can assist your organization develop and implement your environmental compliance programs, with a focus on obtaining full cost recovery for all program activities, while enhancing services to your customers and minimizing the need to increase utility rates on the average utility customer account. This fair and equitable approach to program cost recovery has been successful in helping governments/utilities gain the needed support from the community to implement needed environmental Programs. Our services support the protection of your assets and infrastructure, complying with complicated local, state, federal regulatory requirements, and full program cost recovery. LCG can develop and present your environmental programs.

Wastewater Services

FOG Program Development (Regulation of Grease Traps/Interceptors, Oil/Water Separators, Lift Stations)

Sampling Why should your community/utility implement a comprehensive, proactive FOG Program? Not all communities/utilities have Fats Oils and Grease (FOG) Programs. If your organization/utility is only focused on cleaning your utility assets (sanitary sewer collection system and lift stations), then your assets are most likely suffering from waste overloading, excessive waste accumulation, accelerated asset degradation, and frequent system failures, all common causes of sanitary sewer backups, wastewater sanitary sewer overflows (SSOs), related cleanup costs (both inside and outside of the facility) and regulatory noncompliance/fines. Also, the excessive accumulation of grease in your sanitary sewer system (collection system and lift station) will generate high hydrogen sulfide and low pH conditions in these assets, eventually destroying these expensive concrete manhole and lift station structures. Excessive grease and debris in your wastewater will also harm costly lift station pumps and related equipment. A proactive FOG Program can address this situation by ensuring your customers properly clean and maintain their grease trap/interceptor, oil/water separator wastes and private pump station wastes to keep these discharges out of your community/utility sanitary sewer collection system and lift stations. A comprehensive FOG Program can be the most productive tool in your CMOM compliance tool kit!

Let LCG develop and implement a proactive FOG Program for your organization/utility. The FOG Program Services that LCG can provide your organization include:

  • Perform Direct FOG Program Inspection and Monitoring Services. LCG’s staff has over 35 years of direct FOG Program inspection and monitoring experience. Let LCG provide your community/utility with the most proficient, courteous, knowledgeable and efficient resource to implement your FOG Program. The services included under this option include:
  • Wastewater Code Preparation/Revision Services. To provide legal authority to implement a comprehensive FOG Program, your community’s wastewater utility code will require modification to establish minimum grease removal device (GRU) maintenance, lift station maintenance and waste hauler operational requirements. LCG’s staff has assisted many communities with code revision services and has the experience to help you through this process. LCG can educate your community commission/board of FOG Program benefits and will support your organization through the entire code development/implementation process.
    • LCG will perform Initial Customer Evaluation Inspections for each GRU, and private lift station regulation under your FOG Program. LCG will educate each regulated customer of FOG Program requirements, determine optimal cleaning/maintenance frequency for each asset, and identify minimum repairs (repair, rehabilitate, or replacement) required for each regulated customer to ensure each device is performing as designed, to minimize liability to your organization/utility.
    • LCG will perform Annual Compliance Inspections for each GRU, and private lift station regulation under your FOG Program, to ensure your customer is performing the required scheduled preventative maintenance, and ensure each device is performing as designed and in accordance with your FOG Program requirements.
    • Issue Compliance Requests/Violation Notices during initial and annual compliance inspections, requiring customer compliance activities within prescribed timeframes, to address FOG Grease Removal Device (GRD) & private pump station noncompliance with your FOG Program requirements.
    • FOG Waste Manifest Tracking to ensure customer wastes are properly disposed of and GRDs and Private Pump Stations are properly maintained and cleaned in accordance with the minimum frequency established for the customer.
    • Develop a Residential FOG Education Program. LCG can develop a Residential FOG Education Program to reduce FOG waste discharged by your residential customers. Your Residential Fog Program can target utility customers (directly through bill messages), schools (direct FOG education and/or science experiments pertaining to FOG), HOAs (targeted FOG mailings and/or direct FOG education), and the general community (through news articles, PSAs/commercials, or direct education during community events).
    • Assist Your Organization with the Services Required for you to Implement your FOG Program Directly. If you have adequate staff resources, consider LCG providing you with any combination of the above-listed support services and Staff Training Services to assist your organization’s implementation your FOG Program.

      Waste Hauler Program Development

      Why do you need a Waste Hauler Program for your Community/Utility? Since DEP and EPA does not regulate grease trap/interceptor wastes, and these wastes discharges can cause significant harm to your wastewater collection system, it is important to establish a Waste Hauler Program in your community/utility service area. A Waste Hauler Program can provide minimum waste manifesting and operational procedure requirements for waste haulers servicing GRUs (grease traps/interceptors, oil/water separators) and private pump stations in your community, and enforcement remedies to address waste hauler noncompliance with program requirements. These programs are very simple to develop, implement and maintain. LCG’s staff has over 35 years of Waste Hauler Program development and implementation experience, and is equipped to help you with this service. The specific Services included in Waste Hauler Program Development include the following:

      • Wastewater Code Preparation/Revision Services. To provide legal authority to implement a Waste Hauler Program, your community’s wastewater utility code will require modification to establish minimum program requirements, and enforcement remedies available to the community/utility to address program noncompliance. LCG’s staff has assisted many communities with code revision services and has the experience to help you through this process. LCG can educate your community commission/board of Waste Hauler Program benefits and will support your organization through the entire code development/implementation process.Survey all Waste Haulers and Issue Waste Hauler Program Registration Certificates for each waste hauler providing services to GRUs and private lift stations regulated under your FOG Program. LCG will identify all waste haulers to be regulated, send a program application (requesting the waste hauler identify all vehicles to be used to support FOG Program waste management services in the community), prepare/send each waste hauler a Registration Certificate and Waste Hauler Program information (Waste Hauler Program requirements and enforcement procedures).
      • Issue Compliance Requests/Violation Notices. LCG will issue enforcement correspondence, requiring Waste Hauler compliance activities within prescribed timeframes, to address noncompliance with your Waste Hauler Program and FOG Program requirements.
      • FOG Waste Manifest Tracking Services. LCG can track FOG Manifests to ensure the FOG wastes managed by Waste Haulers are properly disposed of.

        Wastewater Industrial Pretreatment Program Development

        Inspect LCG has the resources and experienced staff to assist you with meeting all requirements under your Industrial Wastewater Discharge Permit. We can assist you with preparing the Baseline Monitoring Report, the initial Permit Application, providing wastewater pretreatment equipment options, design and construct wastewater pretreatment equipment, proposing sampling and inspection requirements, providing the required analytical services, preparing Self Monitoring Reports and submitting these to the regulating agency/utility, and provide enforcement case expert testimony.

        Why should your community/utility implement an Industrial Pretreatment (IP) Program? Did you know that EPA requires all utilities (public or private) to implement an IP Program if any of these situations apply?

        • The total design Wastewater Treatment Facility (WWTF) Capacity (or combination of wastewater treatment facilities operated by the same authority/utility) exceeds 5 million gallons/day (MGD) and receiving pollutants from Industrial Users (customers) which can pass through or interfere with the operation of the WWTF.
        • The WWTF serves any amount of Public Access Reuse Water.
        • If any WWTF receives wastewater from a user with an industrial process that is directly regulated by EPA to require Industrial Pretreatment Program monitoring (Categorical Industrial Users pursuant to 40 CFR Part 403).

        The EPA, DEP or regional utility Director may additionally require a WWTF with a design flow of 5 mgd or less develop an IP Program if a commercial/industrial facility discharges wastewater containing pollutants that: can pass-through the WWTF (untreated); can cause the WWTF’s wastewater, reclaimed water or bio-solids (residuals) to not comply with a regulatory standard, limit or requirement; can cause a process inhibition in any WWTF process; or can cause utility/worker safety issues.

        LCG’s staff has been assisting government/utility clients develop and implement IP Programs for 35 years. Consider LCG and our experienced team provides you comprehensive IP Program Services that include:

        Perform Direct IP Program Oversight, Inspection and Monitoring Services. Let LCG provide your community/utility with the most experienced, proficient, courteous, knowledgeable and efficient resource to implement your IP Program. The services included under this option include:

        • Wastewater Code Preparation/Revision Services. To provide legal authority to implement a comprehensive IP Program, your community’s wastewater utility code will require modification to establish legal authority required by DEP and EPA to implement your IP Program, define IP Program procedural requirements, and required minimum enforcement remedies (Enforcement Response Plan). LCG’s staff has assisted many communities with code revision services and has the experience to help you through this process. LCG can educate your community commission/board of IP Program requirements, benefits, and will support your organization through the entire code development/implementation process.Initial Customer Survey & Survey Inspections. LCG will survey your community/utility wastewater service area to identify all potential commercial/industrial facilities to be evaluated for Best Management Practices (BMP) Program or IP Program monitoring. If (during the Survey) the customer’s wastewater is identified as having the potential to harm the utility’s Wastewater Treatment Facility, contribute more than 5% of the hydraulic loading to the utility’s Wastewater Treatment Facility, and/or be categorized as a Categorical Industrial User (CIU) per EPA 40 CFR Part 403, the customer will be identified as a potential Significant Industrial User (SIU)/CIU, and ECS will then issue the customer an IP Application. If the customer is not identified as a SIU/CIU, but can discharge pollutants of concern to the utility, then the customer will be required to complete a BMP Program Application. LCG will then review all BMP Program Applications and make final recommendation for BMP Program monitoring.
        • BMP Program Registration Certificate Issuance and Annual Inspection Services. If your community/utility is trying to control pollutant discharges, but the customer doesn’t meet the criteria under the IP Program (for IWD Permit issuance), the discharge can be managed under a BMP Program. Customer wastewater discharges of Silver and Mercury can be effectively controlled at a low cost to your customer and to the community/utility through a BMP Program. The customer compliance activities required under the BMP Program Registration Certificate will typically include minimum maintenance requirements for all silver waste pretreatment/capture devices, amalgam/mercury waste capture devices and proper wasterecycling/disposal manifesting.Industrial Wastewater Discharge Permit Issuance. LCG will prepare and issue Industrial Wastewater Discharge (IWD) Permits to all SIUs/CIUs requiring IP Program permit monitoring. These services include a facility inspection to define, map and photograph all appropriate sampling point(s), researching, calculating and applying the appropriate Local Limit, State, or Federal Wastewater Standard to the customer’s wastewater discharge, preparing the permit for utility signature, IWD Permit issuance, and customer education of IWD Permit requirements.Semiannual Compliance Inspection and Sampling Services for each permitted SIU/CIU regulated under your IP Program, as required to ensure your customer is performing the IWD Permit required activities (required wastewater pretreatment, required waste management, required BMPs, maintaining Spill/Slug Control Countermeasures Plans, etc.) in accordance with your IP Program requirements.
        • Customer (SIU/CIU) Self Monitoring Report Compliance Evaluation & Tracking. LCG will review all customer Self Monitoring Reports to evaluate customer wastewater discharge compliance with IWD Permit requirements and ensure the customer is submitting the appropriate number of sample results and reports required.
        • Provide & Maintain IP Program/BMP Program Database to fully implement your IP Program and BMP Program. LCG can provide your organization with a low-cost, industry standard IP Program/BMP Program Database, to track all program activities (Initial Survey, Semiannual/Annual utility inspections, all SIU/CIU and utility sampling data, compliance and follow-up inspection (dates), required compliance activities/due dates, enforcement correspondence issuance dates, and penalties assessed).
        • Issue Compliance Requests/Violation Notices. LCG can prepare all compliance/enforcement correspondence for direct customer issuance or provide this correspondence for utility issuance (as appropriate). All correspondence will be prepared in accordance with the community’s/Utility’s code and enforcement procedure to address all customer noncompliance identified during compliance inspection and sampling services, or customer Self Monitoring Report Services.
        • Prepare Compliance Schedules for IWD Permit incorporation and SIU/CIU implementation. If your customer encounters a compliance issue, LCG can work directly with you and your customer to develop a compliance Schedule (with required compliance activity due dates) with a focus on ensuring you customer comes into compliance as soon as possible. ECS has the experience to guide all parties to a quick resolution to the compliance issue at hand.
        • Provide Expert Testimony during Appeal Hearings, Civil Court Cases.
        • Assist Your Organization with the Services Required for you to Implement your IP Program Directly. If you have adequate staff resources, consider LCG providing you with any combination of the above-listed support services and/or Staff Training Services to support your organization’s implementation of your IP Program.

          Wastewater Environmental Surcharge Program Development and Sampling Support Services

          Why should your community/utility consider developing and implementing an Environmental Surcharge Program? When communities/utilities develop wastewater utility rates, these are done so based on the average wastewater strength expected for a typical wastewater customer (or the average design wastewater strength designed for the Wastewater Treatment Facility). However, many commercial and industrial customer facilities discharge wastewater with higher pollutant concentrations (high strength wastewater). When this occurs, the community/utility rates do not adequately compensate the utility for the extra power and chemical costs to remove these high strength pollutants from the wastewater. This can result in more frequent rate increases on all utility customers (especially difficult on residential customers). However, if your community had an Environmental Surcharge Program, it would have an equitable means of identifying when high strength wastewater discharges are occurring and applying the appropriate (additional) wastewater charges on the customer’s utility bill, if/when this occurs. LCG’s staff has over 35 years of utility experience in developing and implementing Environmental Surcharge Programs. The Environmental Surcharge Program Services provided by LCG include the following:

          Perform Direct Environmental Surcharge Program Oversight, Sampling and Billing Support Services. Let LCG provide your community/utility with the most experienced, proficient, courteous, knowledgeable and efficient resource to implement your Environmental Surcharge Program. The services included under this option include:

          • Wastewater Code Preparation/Revision Services. To provide legal authority to implement an Environmental Surcharge Program, your community’s wastewater utility code will require modification to establish legal authority to implement your Environmental Surcharge Program, and define program procedural billing and sampling requirements. LCG’s staff has assisted many communities with code revision services and has the experience to help you through this process. LCG can educate your community commission/board of Environmental Surcharge Program requirements, benefits, and will support your organization through the entire code development/implementation process.
          • Initial Customer Survey Inspection & Sample Point Evaluation. LCG will survey your community/utility wastewater service area to identify all potential commercial/industrial facilities to be evaluated for Environmental Surcharge Program monitoring. LCG will help the customer complete the required Environmental Surcharge Program Survey (form) and identify an appropriate, representative wastewater sample point. LCG will also provide the customer with industry standard BMPs to help the customer minimize the discharge of program regulated pollutants to their wastewater stream.
          • Environmental Surcharge Program Registration Letter Issuance. After Environmental Surcharge Program Survey review, LCG will issue the customer a letter notifying the customer that they have been registered to participate in the community’s/utility’s Environmental Surcharge Program. The letter will describe all Environmental Surcharge Program requirements, billing procedures, the sampling point (description) to be used for program monitoring, and the utility’s wastewater (Environmental Surcharge bill) billing appeals procedure.
          • Quarterly Environmental Surcharge Program Sampling Services. ECS will collect a sample from your Surcharge Program customer on a quarterly basis. These samples can be analyzed by ECS’s contractor or by the Utility. All sampling services will be performed in accordance with DEP Field Sampling Procedures and will be properly documented.
          • Environmental Surcharge Program Surcharge Result Calculation for Billing Purposes. LCG will review all Environmental Surcharge Program sampling data and define the concentrations of each pollutant regulated under the Environmental Surcharge Program for utility billing purposes.
          • Provide & Maintain Environmental Surcharge Program Database to fully implement your Environmental Surcharge Program. LCG can provide your organization with a low-cost, industry standard Environmental Surcharge Program Database, to track all program activities (Initial Survey, quarterly sampling results, bill calculation results, correspondence issuance dates, and customer requests).
          • Provide Support in Utility Processing of Customer Appeals (of Environmental Surcharge Program Fees).
          • Assist Your Organization with the Services Required for you to Implement your Environmental Surcharge Program Directly. If you have adequate staff resources, consider LCG providing you with any combination of the support services listed above and Staff Training Services required for your organization to fully implement your Surcharge Program.

            Other Services

            Property Procurement Phase I & II Environmental Audit Services

            LCG also specializes in providing Phase I and II Environmental Audits to support prospective property purchase. Phase I and II Environmental Audits are conducted to identify environmental problems (such as chemical spills) or issues connected with the property that might require future expenditures/remediation to meet local, state, and federal environmental guidelines. LCG prides in the level of effort we put forth in conducting this research, researching all property appraiser and government databases, DEP/EPA files, and historic aerial photographs, in person if these records are not available electronically. Combined with our extensive experience in locating and assessing contamination, LCG is the best choice to serve your Phase I and II Environmental Audit needs.

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