Wastewater Permitting and Compliance
Facilities who intend to collect, store, treat, convey, or discharge process wastewater must first evaluate the permitting and other regulatory requirements that may apply to them. Permitting requirements may apply to direct discharges to surface waters, as well as indirect discharges to wastewater treatment plants, also known as Publicly Owned Treatment Works (POTW). Even some non-discharging wastewater operations may be subject to permitting requirements. GT can help facilities navigate various wastewater regulations to determine what requirements apply to them.
Facilities who plan on installing or modifying a wastewater collection, conveyance, storage, treatment or disposal system must obtain a wastewater Permit-to-Install (PTI) prior to beginning construction. Wastewater PTIs grant approval for the construction of a wastewater system and outline the technical and design requirements for the system. Permitting requirements apply to systems that discharge to both surface waters and POTWs, and may also apply to non-discharging operations, such as holding tanks or wastewater evaporators. PTIs may also be required for sludge collection, treatment, and disposal.
Some types of wastewater operations may be exempt from the requirement to obtain a PTI, including pH neutralization, certain types and sizes of oil/water separators, and specified recycle systems.
PTI applications typically require detailed engineering plans, design criteria, and other technical specifications, and must be certified by a Professional Engineer. If the facility intends to discharge to a wastewater treatment plant, it must also obtain approval from the POTW. GT works with clients to assess the permitting and regulatory requirements that apply to new or modified process wastewater systems, and supports clients through the permit application process.
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NPDES Wastewater Discharge Permits
The Clean Water Act prohibits discharges of pollutants to surface waters or a municipal separate storm sewer system (MS4) without a National Pollutant Discharge Elimination System (NPDES) permit. NPDES permits regulate process wastewater discharges to surface waters and establish pollutant limits and monitoring and reporting requirements, among other conditions. Most states, including Ohio, have been delegated authority by US EPA to issue NPDES permits.
There are two types of NPDES permits available for process wastewater discharges – individual and general permits. Individual permits are specific to the discharger and contain requirements based on facility operations, type and amount of discharge, and the condition of the receiving waters. Individual permits may take six months or longer to be issued. General permits, on the other hand, cover multiple dischargers with similar operations and contain standardized terms and conditions. General permits provide an alternative to individual permits for facilities who meet the eligibility criteria given in the permit. Since permit requirements are predetermined, general permit language is available for review prior to applying, and agency processing and review time is reduced, allowing for a quicker turnaround time. Examples of available general permits in Ohio include Non-Contact Cooling Water and Hydrostatic Test Water.
GT assists clients in a variety of industries with preparing both individual and general NPDES permit application packages, as well as navigating permit language and maintaining compliance with monitoring, reporting, and recordkeeping requirements.
Indirect Discharge Permitting
While NPDES permitting covers direct discharges to surface waters or MS4s, the National Pretreatment Program covers indirect discharges, through the issuance of Indirect Discharge Permits (IDPs). The National Pretreatment Program is a component of the NPDES program, and requires industrial or commercial dischargers to treat or control pollutants in their wastewater prior to discharging to a POTW. Some states, such as Ohio, have been authorized by US EPA to implement state pretreatment programs. States may also approve local municipalities to permit discharges to their own POTWs. IDPs implement pretreatment standards that are designed to protect POTW infrastructure and prevent the introduction of pollutants that may pass through or be incompatible with the POTW.
Significant Industrial Users (SIUs) are required to obtain permit coverage through the receiving POTW’s approved pretreatment program, or through the state for discharges to POTWs without approved programs. An SIU is an industrial user who meets any of the following criteria:
- Is subject to categorical pretreatment standards; or
- Discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary, non-contact cooling water, and boiler blowdown); or
- Contributes five percent or more of the average dry weather hydraulic or organic capacity of the POTW, or
- Has a reasonable potential to adversely affect the POTWs operation or to violate any pretreatment standard or requirement.
Many states and municipalities require facilities who do not meet the criteria of an SIU to comply with permit-by-rule or similar provisions.
GT helps clients with indirect discharges determine SIU status, prepare IDP applications, and meet permitting requirements implemented by local municipalities. GT provides support to help clients achieve and maintain compliance with permit limits and requirements.
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