Implementing Regulations into a Permit

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Implementing Regulations into a Permit
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Category Determination

• Identify process(es), raw materials, and
  products.
• Understand process(es) and generated
  wastestreams.
• Contact EPA/State/Local staff for assistance, if
  necessary.
• Determine applicable category/subcategory.
• Note existing vs. new source determination will
  be made for each applicable category.

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Categorical PT Standards vs. Local Limits

• Categorical PT Standards
• Technology
• Production-Based/Concentration
• Restore and Maintain Nations Waterways
• Daily Max and Monthly Average(typ)
• End of Process

• Local Limits
• Technical Evaluation
• Concentration /Mass Based Limits
• Local Environmental and POTW Concerns
• Instantaneous or Daily Maximum only
• End of Pipe

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Application of Categorical PT Standards vs. Local
Limits

• Comparing like units
• Comparing like limits
• Appropriate monitoring points
• end-of-process vs. end-of-pipe

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Regulated Wastestream A
Regulated Wastestream B
Pretreatment
Untreated
M.P.--Categorical Standard Applies Here
POTW
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Combined Wastestream Formula
Regulated A
Unregulated
Regulated B
Dilute
Pretreatment
Monitoring Point
POTW
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Wastestream Types

• Regulated
• Regulated by the categorical standard being
  applied
• Unregulated
• Not regulated by the categorical standard being
  applied
• not a dilute wastestream
• Dilute
• sanitary, boiler blowdown, non-contact cooling,
  storm water, DI backwash streams

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Concentration-Based CWF
CT Alternate concentration limit for the
pollutant
Ci Concentration-based categorical PT standard
Fi Average daily flow of regulated wastestream i
FD Average daily flow of dilute wastestreams
FT Average daily flow through the combined
treatment facility
N Total number of regulated streams
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CWF Considerations

• CWF assumes dilute wastestreams contain no
  pollutants and grants allowance for unregulated
  wastestreams.
• Enforceable as categorical standards
• Established for each regulated pollutant
• May require converting concentration-based
  standards to mass-based or vice-versa.
• Calculated for daily max and monthly (long term)
  averages.
• Must be greater than the analytical detection
  limit.

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Purpose of the Combined Wastestream Formula

• Encourage treatment of unregulated flow which may
  contain significant pollutant concentrations.
• Enable comparison of categorical PT standards and
  local limits.
• Provide CIUs with an option to segregate
  wastestreams or treat a combined flow.

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Wastewater Contribution Permits

• 403.8(f)(1)(iii)--Control the contribution from
  each SIU through a permit or equivalent control
  mechanism.
• Not a contract
• Includes an agreement with the permittee
• Does not provide a PT program with the necessary
  penalty authority.
• Regulates a SIUs discharge to the POTW.
• Conveys all requirements and is strictly
  enforceable.

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Minimum Elements of a Permit

• Effluent Limitations
• Pretreatment Requirements
• Applicable Penalties for noncompliance with
  limitations and requirements
• Statement of Duration
• Statement of Non-Transferability without prior
  notification
• Compliance Schedule

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Permit Language

• The permit acts as the primary notification to
  the IU of its compliance responsibilities.
• Develop concise and complete discharge conditions
  and requirements
• Write as clearly and simply as possible
• Use Specific Language
• Use Strong Language
• Avoid may, could, and should.
• Use shall, required, and must.

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Common Permitting Errors and Omissions

• Improper calculations and standards
• Failure to
• Include specific requirements
• Regulate all discharge points
• Apply the most stringent limit
• Omissions of standard conditions for monitoring,
  reporting, notification or other requirements.
• Typugrafikal airs

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Documentation of Permit Decisions

• Ensures conformance to permit development
  procedures.
• May be used to support permit limits and
  requirements if challenged.
• Reference point for future permit modifications
  or reissuance.
• Ensures consistency if a new permit writer is
  responsible.

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Permit Rationale (Fact Sheet)

• Description of the SIU
• process, treatment, management of wastestreams
• Type and volume of the regulated wastestreams
• Justification for permit limits
• Justification for SIU specific conditions
• time proportional sampling vs. flow proportional
• Continuous monitoring
• Calculation of limits

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Permit Writing Process (Littleton-Englewood)

• Information required for permit development
• Permit Application
• Baseline Monitoring Report
• Developed or Updated
• Spill plans
• Slug Control Plans
• Toxic Organic Management Plan
• Time

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Permit Writing Process (Littleton-Englewood)

• Use permit rationale as the working document for
  permit decisions.
• All information is transferred to the permit
  template.
• All records used to develop permit are kept for
  the life of the issued permit.
• SIU allowed a period to review the draft permit
  prior to issuance.
• All permanent plumbing, treatment, monitoring
  equipment must be in place prior to issuance of
  the permit. (New Sources)