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After Permitting –or- just when you thought you were out of the woods

After Permitting –or- just when you thought you were out of the woods . There is NO After! Between Permitting Compliance Schedules Permit Amendments Permit Extensions Site Applications PQL’s Monitoring Water Regulations. After Permitting. Permit Compliance Read the WHOLE thing

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After Permitting –or- just when you thought you were out of the woods

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  1. After Permitting –or- just when you thought you were out of the woods • There is NO After! • Between Permitting • Compliance Schedules • Permit Amendments • Permit Extensions • Site Applications • PQL’s • Monitoring • Water • Regulations

  2. After Permitting • Permit Compliance • Read the WHOLE thing • Understand ? • Timing, methods, reports • Schedule • Sampling/analysis • Reporting

  3. Compliance Schedules • Allows time for compliance • Monitoring/testing • Studies • Design • Construction • Optimization • Enforceable permit condition !

  4. Permit Amendments • Major • Requires public notice and comment period • Substantial change to effluent • Minor • Reasons For- • Study results • WER • Reasonable potential • PQL • Standards change

  5. Permit Extensions • Continue existing requirements • Completion of studies • Anticipated standards changed • Watershed permitting • Consolidation of facilities

  6. Site Applications • Amendment required: • New process that does NOT increase capacity • Physical changes • Disinfect ion • Gas to Liquid, Liquid to Gas, Cl2 to UV, etc. • Significant changes to- • Secondary treatment • Primary treatment • Digestion • Increase/ decrease in Rated capacity (no construction) • Add reuse facility

  7. PQL • Practical Quantification Level • Permit Limits at or near MDL or LRC • Determined in “clean water” • Wastewater may interfere • Site Specific PQL • Use actual effluent • 7 spiked samples • 3 laboratories • PQL used to measure compliance

  8. Monitoring • Your receiving waters • Upstream • Downstream • Flow • The Regulations • Frequent changes • Your Permit • Read and understand !

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