Wastewater Permit Renewals

Smithfield 2012 Environmental Conference

Susan Murphy, FFI

Wastewater Permit Renewal:Regulatory Checklist

Ensure you have the latest permit application available

What is in your file at the agency? Find outWill you get the same permit reviewer as

last time?Have there been any regulatory changes

that will influence your new permit limits?

>>water quality criteria of receiving water body

>>municipality’s compliance with their NPDES permit—problems?How close to your numerical permit limits

have you been operating?What is your compliance history?When is the application due?

Have you checked ECHO?

• EPA Enforcement and Compliance History Online (ECHO)

Wastewater Permit Renewal:Facility Checklist

Does the description restrict your operation? (“pork processing into patties…”

Are the equipment descriptions, drawings, equipment capacities correct?

What are the construction notification requirements, and has the plant been following these?

Are there any planned new products or expansions possible in the next 5 years (permit term)?

Wastewater Permit Renewal

Follow the instructions (ask questions!)

A word about Water Priority Pollutants…

Has the sanitation contractor reviewed the application chemical list? (and do you provide them a “restriction list” on a regular basis?

What is New at EPA?FOR IMMEDIATE RELEASE

May 9, 2012 

EPA Promotes Safer Alternatives to Nonylphenol Ethoxylates

WASHINGTON — The U.S. Environmental Protection Agency has released the final report on alternatives to nonylphenol ethoxylates (NPE) through the Design for the Environment (DfE) Alternatives Assessment Program. NPEs are widely used surfactants with a range of industrial applications

and are commonly found in consumer products, such as laundry detergents. When released into the environment, they can be persistent and highly toxic to aquatic organisms. The report identifies eight safer

alternatives to NPE that meet EPA’s criteria for safer surfactants.

More information on the DfE Alternatives Assessment Program and the NPEs Report:http://www.epa.gov/dfe/pubs/projects/npe/index.htm

Develop Your “If Only I Could…” List

Can you get reduced sampling or change your reporting burden?

Is the description of the sampling point correct, and would it be better to move it?

Is there a benefit to changing the flow verification requirements?

Does it matter if you increase the flow limitation?

• pH probes are often in the wrong place• Do you need to generate all those paper

charts? • Are you paying for too much flow?• Why do I have to take that sample every

month when the result has not changed in 10 years?

Costs

• Surcharge Rates—Are you subject to a strength category of billing, and is it correct?

• Can you pay a different rate for condensation? Sanitary sewer?

• Is the sampler in the right place, and can you reduce any storm water infiltration?

Permit Language

• Ensure your storm water is included in permit description if there are areas that are part of the effluent

• Question every permit condition, even if it had been in the permit for years

• Agency meeting vs. written review• Is your permit language similar to

other agency issued permits?

Public Comment Period

• You can comment on your own permit

• Agencies prefer you work out the differences before posting for public comment

Milan’s Wastewater Permit

• 1.08 MGD design • DAF, anaerobic contact system, primary

clarification, extended aeration, activated sludge, nitrification and denitrification, secondary clarification, disinfection, and dechlorination

• Direct discharge to a tributary, to a branch of a creek that has designations from livestock watering to recreational full body contact

• Facility had to submit historical data as part of the permit application

Milan’s Permit Renewal

• After receiving a DRAFT, it was decided to meet with the permit engineer and ask questions face-to-face

• Agency department leader attended and interjected information in our favor

• We eliminated system efficiency demonstration ($), retained storm water coverage ($), and eliminated downstream monitoring ($)

• Changed chloride limit to monitor only • Reduced fecal coliform sampling from weekly to

quarterly ($)• Oil and grease was lowered to conventional limits

(15/10 mg/l, daily max and mos. Average, respectively

Milan’s Rainbow