California Wastewater Treatment Plant Operator Water Code § 13625 Attorney Fee Petition Mechanics: SWRCB Operator Certification Database as Primary Welch Anchor (THE ONLY § 13625 Wastewater Treatment Plant Operator Page — DISTINCT FROM Water Treatment Plant Operator H&S Code § 116710, Registered Environmental Health Specialist H&S Code § 106615, and PE Environmental Engineer § 6701; WEF Manual of Practice No. 8 Municipal Wastewater Treatment Plants Advisory [PURE KETCHUM]; APHA/AWWA/WEF Standard Methods 23rd Edition Advisory [PURE KETCHUM]; TWO PRIVATE STANDARDS ON ONE PAGE), CCP § 1021.5 Private Attorney General Mandatory Attorney Fees

Statutory Framework: Water Code § 13625 and SWRCB Grade I–V Operator Certificate — Wastewater Treatment Plant Operator Requirements, Scope of Practice, WEF MOP 8 [PURE KETCHUM], Standard Methods 23rd Edition [PURE KETCHUM], and CCP § 1021.5 Mandatory Attorney Fees

California Water Code § 13625 — enacted as part of the Wastewater Treatment Plant Operator Certification Law (§§ 13625–13672) — requires that any person who operates a wastewater treatment plant hold a current Wastewater Treatment Plant Operator Certificate issued by the State Water Resources Control Board (SWRCB). Certificates are issued at five Grade levels corresponding to plant size, complexity, and treatment processes: Grade I covers entry-level positions at small plants with limited unit processes; Grade II covers plants with conventional primary and secondary treatment; Grade III is required for large plants with biological nutrient removal, membrane bioreactors, or advanced secondary processes; Grade IV covers large or complex facilities with tertiary treatment, advanced biological nutrient removal, or recycled water production capacity; Grade V — the highest grade — is required for large, complex, or multiple-unit water reclamation facilities. Specific education, experience, and examination requirements for each Grade are established in Title 23 CCR §§ 3680–3700. § 13627 expressly prohibits any person from operating a wastewater treatment plant without holding the required SWRCB certificate of the appropriate Grade; a person who operates a plant without the required Grade certificate commits § 13627 uncertified operation. § 13627 violations are actionable under CCP § 1021.5 when the litigation enforces certified operator requirements as a public right protecting California receiving waters, downstream communities, and the public from the discharge risks arising from uncertified wastewater treatment plant operation. Primary Welch anchor: SWRCB Operator Certification (OC) database (name and certificate number search).

WEF MANUAL OF PRACTICE NO. 8 (DESIGN OF MUNICIPAL WASTEWATER TREATMENT PLANTS), 6TH EDITION ADVISORY — THE ONLY PAGE IN THE FEE-PETITION-MECHANICS SERIES WITH A WEF MOP 8 ADVISORY — PURE KETCHUM: The Water Environment Federation (WEF, founded 1928, Alexandria VA) is a private nonprofit professional organization serving water quality science and engineering professionals including wastewater treatment plant operators, engineers, and researchers. WEF Manual of Practice No. 8 (Design of Municipal Wastewater Treatment Plants, 6th Edition) is the comprehensive technical reference for municipal wastewater treatment plant design and operations; it is widely used by certified operators and engineers as the definitive guidance document for treatment process operational parameters and decision criteria. Key WEF MOP 8 provisions applicable to wastewater treatment plant operator practice include: (1) Chapter 3 — operational monitoring protocols for certified operators including the bypass authorization decision criteria specifying that a certified operator must evaluate available treatment unit capacity, contact the Regional Water Quality Control Board (RWQCB) for bypass authorization, and document the bypass event in compliance with NPDES permit special conditions before routing any flow around secondary treatment units; Chapter 3 also establishes aeration basin mixed liquor suspended solids (MLSS) target control ranges (typically 1,500–4,000 mg/L for conventional activated sludge) and secondary clarifier solids loading rate maximums (typically 3–6 lb/ft²/day) that certified operators are trained to monitor and control; (2) Chapter 15 — biological nutrient removal (BNR) process operational parameters including dissolved oxygen setpoints for nitrification/denitrification zones, internal recycle flow rate control, and sludge retention time (SRT) management for nitrogen and phosphorus removal; (3) Chapter 16 — solids handling and dewatering operational requirements including biosolids sampling and characterization protocols, dewatering equipment operational targets, and land application preparation requirements. An uncertified operator who bypasses the secondary clarifier without following the WEF MOP 8 Chapter 3 bypass decision protocol — omitting the RWQCB bypass authorization notification — commits documented WEF MOP 8 operational deficiencies. WEF MOP 8 creates no statutory fee-shifting; it is a PURE KETCHUM advisory.

STANDARD METHODS FOR THE EXAMINATION OF WATER AND WASTEWATER, 23RD EDITION (APHA/AWWA/WEF) ADVISORY — THE ONLY PAGE IN THE FEE-PETITION-MECHANICS SERIES WITH A STANDARD METHODS 23RD EDITION ADVISORY — PURE KETCHUM: Standard Methods for the Examination of Water and Wastewater, 23rd Edition, is published jointly by the American Public Health Association (APHA, founded 1872, Washington DC), the American Water Works Association (AWWA, founded 1881, Denver CO), and the Water Environment Federation (WEF, founded 1928, Alexandria VA) — three major private nonprofit professional organizations in the water and public health fields. Standard Methods is the authoritative analytical methods reference for water and wastewater quality analysis, widely referenced by NPDES permits, SWRCB regulations, and state primacy agency guidance as the accepted analytical framework for compliance monitoring. Key Standard Methods provisions applicable to wastewater treatment plant operator practice include: (1) Section 4500-O — Dissolved Oxygen measurement methods for biological treatment process monitoring, specifying membrane electrode and Winkler titrimetric methods for accurate DO measurement in aeration basins and secondary clarifiers; (2) Section 9220 — membrane filtration and multiple-tube fermentation total coliform and Escherichia coli (E. coli) methods applicable to recycled water effluent compliance monitoring under Title 22 CCR, establishing the approved analytical procedures that certified operators must use when verifying that recycled water discharge meets the total coliform and E. coli limits established in CCR Title 22 § 60301.320 before discharge; (3) Section 2540 — total solids, total suspended solids, and volatile suspended solids gravimetric analytical methods required for accurate biosolids percent solids determination before land application, specifying the laboratory oven-drying temperature (103–105°C), crucible preparation, and weighing protocol for precise gravimetric percent solids analysis. An uncertified operator who substitutes a visual estimate for the Standard Methods Section 2540 gravimetric biosolids percent solids test — resulting in inaccurate land application loading rate calculations — commits documented Standard Methods analytical protocol omissions. Standard Methods creates no statutory fee-shifting; it is a PURE KETCHUM advisory.

Three-Track Harm: Secondary Clarifier Bypass BOD 245 mg/L vs 30 mg/L NPDES Limit RWQCB Penalty ($285K), Recycled Water E. coli Standard Methods Test Omitted CDPH Emergency Suspension ($195K), and Biosolids Gravimetric Test Omitted Land Application Permit Exceedance RWQCB Citation ($95K)

• UNCERTIFIED OPERATOR AT SAN JOAQUIN VALLEY PUBLICLY OWNED TREATMENT WORKS (POTW) SERVING 28,000 POPULATION EQUIVALENT (SWRCB OC DATABASE CONFIRMS NO GRADE III OR GRADE IV CERTIFICATE) BYPASSES SECONDARY CLARIFIER DURING PEAK WET-WEATHER FLOW SURGE WITHOUT RWQCB AUTHORIZATION AND WITHOUT WEF MOP 8 CHAPTER 3 BYPASS DECISION PROTOCOL — WEF MOP 8 CHAPTER 3 REQUIRES CERTIFIED OPERATOR TO EVALUATE AVAILABLE TREATMENT CAPACITY AND CONTACT RWQCB FOR BYPASS AUTHORIZATION BEFORE ROUTING UNTREATED WASTEWATER AROUND SECONDARY TREATMENT — PRIMARY EFFLUENT BYPASSED DIRECTLY TO DELTA-MENDOTA CANAL TRIBUTARY FOR 4.5 HOURS — NPDES PERMIT EFFLUENT LIMIT EXCEEDANCE: BOD 245 MG/L vs 30 MG/L DAILY MAXIMUM; TSS 318 MG/L vs 30 MG/L DAILY MAXIMUM — RWQCB MANDATORY MINIMUM PENALTY PURSUANT TO WATER CODE § 13385 — $285,000 PENALTY AND CORRECTIVE ACTION ORDER. A San Joaquin Valley POTW operating under an NPDES permit and serving a population equivalent of 28,000 employed a person as senior plant operator who held no SWRCB Grade III or Grade IV Wastewater Treatment Plant Operator certificate (SWRCB OC database confirmed zero Grade III or higher certificate records for the operator’s name and any certificate number appearing on plant discharge monitoring reports). During a peak wet-weather event in the third week of January, influent flow rates to the facility surged to 185% of design average daily flow, overwhelming the secondary treatment aeration basins and pushing secondary clarifier solids loading rates above the WEF MOP 8 Chapter 3 maximum of 6 lb/ft²/day. WEF MOP 8 Chapter 3 requires a certified operator facing secondary clarifier overload to implement emergency aeration adjustments, activate standby clarifier capacity, evaluate available remaining treatment capacity across all unit processes, and — only if treatment capacity is genuinely insufficient — contact the RWQCB Regional Board duty officer for advance bypass authorization before routing any flow around secondary treatment. The uncertified operator, lacking training in the WEF MOP 8 Chapter 3 bypass decision protocol, made a unilateral decision to route influent flows directly from the primary clarifier effluent channel around the secondary treatment units via the bypass valve, without contacting the RWQCB and without evaluating whether operational measures could have managed the flow surge. Primary effluent was discharged to a Delta-Mendota Canal tributary for 4.5 continuous hours; NPDES compliance sampling of the effluent detected BOD at 245 mg/L against the 30 mg/L daily maximum limit and TSS at 318 mg/L against the 30 mg/L daily maximum. The RWQCB Central Valley Region issued a Mandatory Minimum Penalty (MMP) under Water Code § 13385 for the unauthorized bypass and the resulting NPDES effluent limit exceedances, assessing a penalty of $285,000 plus a corrective action order requiring the facility to hire a certified Grade IV operator and implement a bypass response protocol consistent with WEF MOP 8 Chapter 3 criteria.
• UNCERTIFIED OPERATOR AT LOS ANGELES COUNTY WATER RECYCLING FACILITY FAILS TO PERFORM STANDARD METHODS SECTION 9220 E. COLI CONFIRMATION TESTING BEFORE DISCHARGING RECYCLED WATER TO AGRICULTURAL IRRIGATION DISTRIBUTION SYSTEM — TITLE 22 CCR SECTION 60301.320 REQUIRES CERTIFIED OPERATOR TO VERIFY THAT EACH RECYCLED WATER SAMPLE MEETS TOTAL COLIFORM AND E. COLI EFFLUENT LIMITS USING STANDARD METHODS BEFORE DISCHARGE — UNCERTIFIED OPERATOR SUBSTITUTES RAPID INDICATOR STRIP TEST NOT APPROVED BY DDW FOR TITLE 22 EFFLUENT COMPLIANCE — THREE DISTRIBUTION SYSTEM SAMPLES CONFIRMED COLIFORM POSITIVE ON NEXT-DAY STANDARD METHODS CONFIRMATION — CDPH ISSUES EMERGENCY RECYCLED WATER USE SUSPENSION ORDER COVERING 340 AGRICULTURAL ACCOUNTS — EMERGENCY RETESTING, DISTRIBUTION SYSTEM FLUSH, AND PUBLIC NOTIFICATION — $195,000 REMEDIATION AND TESTING COSTS. A Los Angeles County regional water recycling facility producing Title 22 CCR recycled water for agricultural irrigation distribution employed a person as the primary effluent monitoring operator who held no SWRCB Wastewater Treatment Plant Operator certificate of any Grade (SWRCB OC database confirmed zero certificate records). Title 22 CCR § 60301.320 requires that the certified operator of a water recycling facility verify, using Standard Methods-approved analytical procedures, that recycled water effluent meets the total coliform and E. coli limits specified in the recycled water permit before discharge to the distribution system; the permit required a total coliform limit of 2.2 MPN/100 mL (7-day median) and E. coli not detected per 100 mL by Standard Methods Section 9220 membrane filtration. The uncertified operator, instead of performing the Standard Methods Section 9220 membrane filtration E. coli analysis, substituted a rapid colorimetric indicator strip test product that had not been approved by DDW as an acceptable alternative method for Title 22 recycled water effluent compliance verification; the indicator strips showed negative results, and the uncertified operator authorized discharge to the agricultural irrigation distribution system serving 340 farm accounts. On the next business day, routine distribution system confirmation samples collected by a CDPH-contracted laboratory using Standard Methods Section 9220 membrane filtration detected total coliform presence in three of four distribution system sample points. CDPH issued an emergency recycled water use suspension order covering all 340 agricultural accounts connected to the distribution system, requiring immediate cessation of irrigation, emergency distribution system flushing and retesting, and public notification to all permit holders. The facility incurred $195,000 in emergency laboratory testing, distribution system flushing contractor costs, public notification, and regulatory consultation fees, with the CDPH Order specifically documenting the Standard Methods Section 9220 analytical method substitution by an uncertified operator as the root cause of the compliance failure.
• UNCERTIFIED OPERATOR AT CENTRAL COAST MUNICIPAL WASTEWATER AGENCY USES VISUAL AND TACTILE ESTIMATE OF DEWATERED BIOSOLIDS PERCENT TOTAL SOLIDS WITHOUT PERFORMING STANDARD METHODS SECTION 2540 GRAVIMETRIC PERCENT SOLIDS DETERMINATION — STANDARD METHODS SECTION 2540 REQUIRES LABORATORY GRAVIMETRIC MEASUREMENT OF BIOSOLIDS DRY WEIGHT AND WET WEIGHT FOR ACCURATE PERCENT SOLIDS DETERMINATION BEFORE BIOSOLIDS ARE APPLIED TO AGRICULTURAL LAND — OPERATOR ESTIMATES 28% SOLIDS BY VISUAL INSPECTION; ACTUAL PERCENT SOLIDS 18% BY GRAVIMETRIC ANALYSIS — LAND APPLICATION RATE AT PERMITTED ACREAGE DELIVERS 56% EXCESS NITROGEN LOADING ABOVE PERMITTED AGRONOMIC RATE — RWQCB BIOSOLIDS LAND APPLICATION ORDER VIOLATION CITATION — $95,000 ADMINISTRATIVE CIVIL LIABILITY PLUS MANDATORY THIRD-PARTY BIOSOLIDS MANAGEMENT AUDIT. A Central Coast municipal wastewater agency producing Class B biosolids for agricultural land application under a RWQCB Biosolids Land Application Order employed a person as the biosolids management operator who held no SWRCB Wastewater Treatment Plant Operator certificate of any Grade (SWRCB OC database confirmed zero certificate records). Standard Methods Section 2540 establishes the gravimetric procedure for determining total solids and percent solids in wastewater sludge and biosolids: the operator must collect a representative sample of dewatered biosolids, place a known wet weight aliquot in a pre-tared evaporating dish, dry the sample in an oven at 103–105°C to constant weight, and calculate percent solids from the ratio of dried mass to wet mass; this gravimetric determination is required for accurate biosolids land application rate calculations because the agronomic nitrogen loading rate permitted by the RWQCB Biosolids Land Application Order is expressed as dry-weight tons per acre. The training curriculum for SWRCB Grade III and IV certificate operators specifically covers Standard Methods Section 2540 biosolids percent solids determination as a prerequisite to biosolids land application. The uncertified operator, lacking this training, estimated percent solids by visual and tactile assessment of the dewatered biosolids cake — reporting 28% solids based on the subjective appearance of the press cake — without performing any Standard Methods Section 2540 gravimetric analysis. Independent sampling and gravimetric analysis conducted by a third-party laboratory at the RWQCB’s direction established actual percent solids of 18% — a 10-percentage-point underestimate. Using the erroneous 28% solids figure to calculate land application rates, the uncertified operator’s biosolids loading at the permitted acreage delivered 56% excess nitrogen above the permitted agronomic loading rate, triggering a RWQCB Biosolids Land Application Order violation; the RWQCB issued an Administrative Civil Liability of $95,000 plus a mandatory third-party biosolids management audit and requirement for certified operator employment verification before any further land application operations.

Distinct From Water Treatment Plant Operator (H&S Code § 116710), Registered Environmental Health Specialist (H&S Code § 106615), and PE Environmental Engineer (Bus. & Prof. Code § 6701 PE-EnvE)

• DISTINCT FROM Water Treatment Plant Operator (H&S Code § 116710 T1–T5 SWRCB DDW certificate) — A Water Treatment Plant Operator holds a SWRCB DDW T1, T2, T3, T4, or T5 Drinking Water Treatment Plant Operator Certificate issued under H&S Code § 116710 and the Safe Drinking Water Act (§§ 116270–116800) authorizing operation of potable water treatment facilities; a Wastewater Treatment Plant Operator holds a SWRCB Grade I, II, III, IV, or V certificate under Water Code § 13625 authorizing operation of wastewater treatment plants treating municipal sewage before discharge; the two programs are administered by separate SWRCB divisions, authorize different treatment processes, use separate certification databases, and are governed by entirely different statutory frameworks: the § 13625 fee petition requires confirming absence of a Grade certificate in the SWRCB OC database; a § 116710 fee petition requires confirming absence of a T-certificate in the DDW Operator Certification database; neither certificate authorizes the practice covered by the other; a Grade IV Wastewater Treatment Plant Operator certificate does not authorize operation of a potable water treatment facility.
• DISTINCT FROM Registered Environmental Health Specialist (H&S Code § 106615 CDPH REHS/RS credential) — A Registered Environmental Health Specialist (REHS/RS) holds a CDPH credential under the Environmental Health Specialist Registration Act authorizing food safety inspections, vector control advisory services, environmental health assessments, and sanitary surveys of water and wastewater facilities from an inspection perspective; a REHS does not hold a SWRCB Grade I–V Wastewater Treatment Plant Operator certificate and is not authorized to perform the daily operational functions of a certified wastewater treatment plant operator including aeration basin process control, secondary clarifier solids management, biological nutrient removal process monitoring, biosolids management, and NPDES compliance monitoring under Standard Methods: the two credentials are issued by different state agencies (CDPH vs. SWRCB), are governed by different statutes (H&S Code § 106615 vs. Water Code § 13625), and authorize entirely different professional activities; a REHS who performs wastewater treatment plant operational functions without a Grade certificate commits § 13627 uncertified operation regardless of REHS licensure.
• DISTINCT FROM PE Environmental Engineer (Bus. & Prof. Code § 6701 PE-EnvE BPELSG designation) — A PE Environmental Engineer (PE-EnvE) is licensed under the Professional Engineers Act to design wastewater treatment systems, prepare engineering reports for NPDES permit applications, stamp treatment facility plans and specifications, conduct engineering analyses of treatment plant performance and NPDES compliance, and prepare biosolids management engineering reports; a PE-EnvE is not required to hold a SWRCB Grade I–V Wastewater Treatment Plant Operator certificate and is not authorized to perform the daily operational functions of a certified wastewater treatment plant operator including secondary clarifier process control, WEF MOP 8 Chapter 3 bypass decision protocol execution, Standard Methods analytical testing for NPDES compliance monitoring, and biosolids percent solids gravimetric analysis; the § 13625 fee petition targets uncertified operation of a wastewater treatment plant, not unlicensed engineering design of wastewater treatment infrastructure: PE-EnvE and SWRCB Grade certificate are issued by different agencies (BPELSG vs. SWRCB), govern different professional activities (engineering design vs. plant operation), and are required by different statutes (§ 6701 vs. § 13625); the two credentials serve entirely different and non-overlapping professional practice functions.

Billing Gaps 1–3 Summary (13.25 hrs/yr = $3,975–$6,625/yr)

Frequently Asked Questions