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Industrial Wastewater Permits

Industrial Wastewater Permits. 2014 Environmental Trade Fair. Karen Holligan. Overview. Processing the permit application Filling out the permit application – help us to help you. Permitting Process. Administrative review Technical review Public notice / (public comments)

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Industrial Wastewater Permits

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  1. Industrial Wastewater Permits 2014 Environmental Trade Fair Karen Holligan

  2. Overview • Processing the permit application • Filling out the permit application – help us to help you

  3. Permitting Process • Administrative review • Technical review • Public notice / (public comments) • (EPA review / objections) • (Public meeting / contested case hearing) • Agency decision – issued / denied

  4. Processing Time Frames • Newapplication – 330 days • Major amendment • Major facilities – 330 days • Minor facilities – 300 days • Renewal • Major facilities – 330 days • Minor facilities – 300 days

  5. Processing Time Frames • Timeframes may be extended if: • EPA issues objections to the draft permit • TCEQ receives request(s) for public meeting or contested case hearing

  6. Administrative Review • Administrative report • Applicant and site information • Notice information • Landowner information • Respond promptly to any requests for additional information. Delaying your response delays your permit.

  7. Administrative Review • Notice of Receipt of Application and Intent to Obtain a Water Quality Permit (NORI) – “first notice” • Publish promptly and return documentation to the Chief Clerk’s Office (CCO) • Draft permit cannot be filed with the CCO if NORI process is incomplete – this may delay your permit Notice # 1

  8. Technical Review • Water Quality Standards • Uses and criteria • Antidegradation • Endangered species • Critical Conditions • Critical flows or mixing conditions • Mixing zone definition

  9. Technical Review • Dissolved Oxygen (DO) Modeling • Impact of discharge(s) on DO • Water body impairments • Completed total maximum daily loads (TMDLs) • Biomonitoring • Whole effluent toxicity (WET) testing or limits • Species, frequency, dilutions

  10. Technical Review cont. • Agronomy (disposal by irrigation) • Crops • Soil testing • Hydrogeology • Pond-lining requirements • Buffer zones • Groundwater monitoring • Industrial Permits

  11. Industrial Permits - Development • Data completeness review • Compliance history • Self-reported effluent data • Technology-based effluent limits • Water quality-based effluent limits • Final effluent limits – most stringent of tech-based, water quality-based, and existing permit limits

  12. Industrial Permits - Review • Team leader • Applicant • (Legal) • (Other technical staff)

  13. Industrial Permits - Review • Public – Notice of Application and Preliminary Decision (NAPD) – “second notice” • Again, publish promptly and return documentation to the CCO. • If comments are received, permit writer and Legal prepare a response to comments document • If public meeting is held, comment period typically extended to end of meeting. Notice # 2

  14. Industrial Permits - Review • (EPA review – approve or issue objections – respond to EPA objections) • (Request(s) for contested case hearing – granted or denied) • Permit issued or denied

  15. Filling out the Application • If an item is not applicable, enter “N/A”. Do not leave the item blank. • If you’re not sure how to fill out part of the application: • Read the instructions (!) • Call the Water Quality Division (512-239-4671) and ask to speak with an industrial permit writer. • Provide complete information each time, even for renewals.

  16. Technical Report - Tips • Item 1 • Describe all processes that generate wastewater. • Include legible facility maps. • Item 2 • Describe treatment systems, if any. Err on the side of too much detail. • Include flow schematic with water balance. • Item 3 • Impoundments – Provide all information such as liner type, storage volume, and surface area.

  17. Technical Report – Tips cont. • Item 4 - Outfall information • List all contributing waste streams. • Include volumes of all waste streams, even if they are very small. • Include % of total flow volume of each waste stream. • Be sure that the sum of all waste percentages equals 100%. • Be sure information in table is consistent with flow schematic/water balance.

  18. Technical Report – Tips cont. • Items 12-14 • Amendments/modification requests – try to include all changes up front. • Not including all changes up front may cause significant delay in processing the permit application.

  19. Technical Report – Worksheet 1.0 EPA Effluent Categorical Guidelines • Item 1 - Include all parts and subparts of Title 40 Code of Federal Regulations (CFR) that apply. • Item 2 – Include all production data (in appropriate units) for each category and subcategory. • Item 3 – Provide breakdown of process vs. non-process wastewater. • Item 4 – Provide complete information on processes, 40 CFR Parts and Subparts, and start dates so that permit writer can determine whether New Source Performance Standards apply.

  20. Technical Report – Worksheet 2.0 Pollutant Analyses • Plan ahead • Begin sampling and analyzing effluent so that all required data can be submitted with the application. • Effluent data is required for renewal applications. • Applications are no longer processed without analytical data. Exceptions: • new facilities • facilities with no discharges due to drought or other circumstances • Analytical labs must be NELAC-certified.

  21. Technical Report – Worksheet 2.0 Pollutant Analyses • Minimum analytical levels (MALs) in the June 2010 Implementation Procedures were approved by EPA on July 12, 2013. • Many have been lowered, e.g.: • Total copper: 10 µg/L 2 µg/L • Total lead: 5 µg/L 0.5 µg/L • Permit application forms are being updated and are scheduled to be available on July 14, 2014.

  22. Technical Report – Worksheet 3.0Texas Land Application Permits - TLAPs • Complete all applicable information (irrigation, evaporation, or both). • Provide cropping plan if irrigating.

  23. Technical Report – Worksheet 3.0Texas Land Application Permits - TLAPs • Provide pollutant analysis. • Analytical labs must be NELAC-certified (signature required on page 17). • Fill out all required pollutant analysis tables. • In Table 7, include data for all parameters regulated in the permit. • In Table 8, include data for all parameters not regulated in the permit.

  24. Technical Report – Worksheet 3.1TLAPs Water balance • Needed to calculate allowable land application rates and storage volumes (when storage is required). • Information needed includes: • Curve number (CN) • Effluent conductivity (Ce) • Maximum allowable conductivity of soil solution (CL) • Irrigation efficiency (K)

  25. Forms and Instructions Application forms and instructions, plus additional information, are available at the following TCEQ web site: http://www.tceq.texas.gov/permitting/wastewater/industrial/TPDES_industrial_wastewater_steps.html This page also includes a link to Spanish language notice templates.

  26. For More Information: Phone: 512-239-4671 Water Quality Division Industrial Permits Team Questions ?

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