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ISAT 422: Environmental
Management
Water Regulations
"Clean Water Act (CWA)" = Water Pollution Control Act of 1972
Amended by Clean Water Act of 1977 (influenced by 1976 consent decree pursuant to NRDC’s suit of EPA re: toxics)
Amended again by the Water Quality Act of 1987
ISAT 422: Environmental
Management
NPDES Permit Program
NPDES: National Pollutant Discharge Elimination System
Point sources into waters of US require permit
State by state WQS (Water Quality Standards) used, similar to NAAQS, based on intended use of water
ISAT 422: Environmental
Management
Control Technologies
Applied on an industry-by-industry basis BAT: Best Available Technology
Economically Achievable– For “priority pollutants” (126+ toxics)
ISAT 422: Environmental
Management
BPT: Best Practicable Control Technology Currently Available Intended to capture existing sources For pollutants requiring a substantial level
of control To have expired to BAT by July 1, 1983
ISAT 422: Environmental
Management
BCT: Best Conventional Pollutant Control Technology
Added by 1977 amendments, extended by 1987
Considered by Congress to be comparable to secondary treatment
For conventional pollutants:– BOD, TSS, pH, Fecal coliform, Oil and grease
(40 CFR 401.16)
ISAT 422: Environmental
Management
Pretreatment Program
Industrial waters discharged into POTW are required to be pretreated to prevent damage to or overwhelming of POTW
General, Categorical, and Local standards may apply
ISAT 422: Environmental
Management
General
“Significant” industrial users (25,000 gal/day, or 5% of either the avg dry weather hydraulic capacity or organic capacity of the POTW).
Prohibit flammables or explosives, pH < , flow limiting solids or liquids, excessive temperature, or oils which may inhibit POTW operations
ISAT 422: Environmental
Management
Categorical
Based on industry category Limits on end-of-pipe discharges
ISAT 422: Environmental
Management
Local
Local POTW greater than 5 MGD required to develop local pretreatment program requirements
ISAT 422: Environmental
Management
Others
New Source Performance Standards– Somewhat more stringent categorical standards
for new sources Stormwater
– Stormwater discharge permits Wetlands
ISAT 422: Environmental
Management
Enforcement
Civil Liabilities:– Class 1 Civil Penalty
$10,000 per violation $25,000 maximum per penalty Written notice of intent to issue order Administrative hearing, if requested within 30 days
– Class II Civil Penalty $10,000 per violation $125,000 maximum per penalty Legal procedure at 5USC554
ISAT 422: Environmental
Management
Criminal Liabilities:
ISAT 422: Environmental
Management
Criminal Liabilities:
ISAT 422: Environmental
Management
Criminal Liabilities:
ISAT 422: Environmental
Management
Water Permits
NPDES – Application 180 days in advance of activity!– Limits on stream, limits on bypass, reporting of
upsets– Discharge Monitoring Reports (DMR)
ISAT 422: Environmental
Management
Water Permits (2)
Standard clauses:– Bypass– Upset– Halt or abate– Duty to mitigate– Notification– Operation and maintenance
Stormwater Permits– NOI (Notice of Intent) regarding activities, impervious
cover, &c
ISAT 422: Environmental
Management
Water Pollution Control
Start with water balance around plant– Account for all sources and sinks– Characterize possible contaminants of water
Primary Industrial Types– Process water– Cooling water– Sanitary water (including kitchens)– Importance of the inventory
