Industrial User Pretreatment Permits IUPs

1
Industrial User Pretreatment Permits (IUPs)

• An introduction to IUPs

2
SIU Responsibility versus POTW Responsibility

• SIU is Permittee of POTW
• Comply with SUO and IUP
• Keep POTW informed of SIU operations, including
  notification of changes before they make the
  change.
• POTW is Control Authority over SIUs
• Develop and Implement DWQ approved Pretreatment
  Program
• Control Industrial Users
• POTW is permittee of Approval Authority (DWQ)

3
POTWs Role

• POTWs role toward SIUs same as DWQs role toward
  NPDES and Non-discharge permittees
• Think of POTW and its collection system as a
  river basin
• LTMP/STMP and HWA versus ambient monitoring
  network, basin plans, level Bs, TMDLs, reasonable
  potential analysis
• SUO versus NCGS and .0100s and .0200s
• Permits, Compliance, Enforcement, Inspections and
  Audits
• PAR versus QNCR
• Goal is same - clean environment

4
IUP Industrial User Pretreatment Permit

• Control Mechanism document issued by POTWs to
  specify how and under what conditions an
  Industrial User may discharge
• Purpose is to protect POTW and environment.
• Issued to
• SIU Significant Industrial User
• CIUCategorical Industrial User
• non-SIU-non-significant industrial users
• Includes limits, monitoring, reporting, general
  and specific conditions.

5
IUPs - POTW Responsibility

• Identify all SIUs (NCAC 02H .0905-.0907)
• Issue IUPs to all SIUs (NCAC 02H .0916(a))
• Upon issuance, submit all SIU IUPs to DWQ for
  approval (NCAC 02H .0917(a))
• If necessary, revise SIU IUPs as required by DWQ
  (NCAC 02H .0917)
• If necessary, address SIU adjudication of IUP
  (NCAC 02H .0916(c)(5))

6
IUPs - POTW Responsibility

• IUPs cannot be issued for a period to exceed 5
  years (NCAC 02H .0905-.0907)
• POTW must enforce requirement that SIU notify
  POTW of changes before changes are made, and POTW
  must revise IUP as necessary before changes can
  begin
• Model SUO, Section 4.2(I), and 5.5
• Generic IUP, Part II, 25

7
IUPs - POTW Responsibility

• IUPs cannot be transferred
• Model SUO, Section 4.2(l)
• Generic IUP, Part II, 19
• new SIU owner must submit letter stating no
  changes made from previous application, or
  alternatively, POTW may require new owner to
  complete new application.
• Need new SIU to designate new signatory authority

8
IUPs - POTW Responsibility

• IUPs cannot be transferred (continued)
• Modify IUP using new company name, or if new
  application, may issue new IUP
• new or modified IUP can have same IUP number or
  new IUP number, up to POTW and/or SIU.

9
IUPs - DWQ Responsibility

• aide POTWs in SIU/CIU determinations
• Approve IWS (NCAC .0905-.0907)
• aide POTWs in writing IUPs
• Approve IUPs (NCAC .0917)

10
IUP Cover page

• IUP number
• SIU name and address
• POTW name and address
• effective date, expiration date, and signature
  date.
• Legal authority under which IUP is listed
• categorical number

11
IUPs - Dates

• IUP effective date is date IUP or IUP
  modification comes into effect.
• IUP signature date is date IUP is signed. May
  or may not be same as IUP effective date.
• Signature date cannot be later than effective
  date, i.e., effective date and modification
  effective date cannot be retroactive (NCAC 02H
  .0916(c)(7(C))
• IUP expiration date is date IUP or IUP
  modification expires.

12
IUPs - Dates

• Listed in several places in IUP.
• Cover page
• Permit History
• Previously called Modification History
• Limits page

13
Permit History

• A history of the IUP activity
• Previously called Modification History
• Each entry is identified as an IUP renewal or IUP
  modification
• Effective date.
• List of changes made
• can be brief For example, changed limits or
  Revised Part III 1, and added Part III, 8.
• Is on-going, i.e., does not start over with IUP
  renewal, even for name changes
• can be inside IUP or attached to IUP

14
Limits Page

• Effective and Expiration Date
• Pipe Number
• Limits
• Monitoring
• POTW or SIU
• sample type
• reference to Part II or Part III
• Followed by Definitions page
• Definitions and other explanations for terms and
  abbreviations on limits page

15
General Conditions

• Very important
• Most limits violation caused by underlying
  violation of general condition
• changed process chemicals
• increased production
• slug load
• pretreatment unit failure or overload

16
Specific Conditions

• Very important
• Conditions specific to one SIU
• flow requirements
• categorical requirements
• Slug/Spill Control Plan

17
Categorical SIUs

• Federal categorical regulations in 40
• Cover a specific category of industries.
• Contain specific limits for specific pollutants
• Ask for help from DWQ

18
Allocation Table (AT)

• SIU IUP limits
• compute pounds/day
• Sum of SIU permitted load
• Compare against the MAHL and MAIL
• No over allocation!

19
Allocation Table (AT)
20
IUP FLOW CHART
21
What to submit to SIU

• Transmittal letter, including right to adjudicate
• IUP
• draft versus final, make it clear in submittal
  which it is
• possibly synopsis and allocation table

22
What to submit to DWQ

• All pages submitted to SIU
• transmittal letter
• IUP
• draft versus final, make it clear in submittal
  which it is
• synopsis, including application (if new) and
  inspection
• allocation table

23
IUP Renewal versus IUP Modification

• IUP renewal when SIU completes new application
• starts a new 5 year cycle
• typically done when previous IUP expires
• sometimes SIU completes new application before
  IUP expires
• ex. major expansion, ownership change
• IUP modification typically done when changes
  needed before end of 5 year cycle
• change or add a limit, revise a date or condition

24
Writing the Right Permit

• Creating a permit that
• Protects the POTW
• Environmentally sound
• Technically feasible
• Judicially defensible
• There is a delicate balance between these goals
  and protecting the POTW!

25
IUP Industrial User Pretreatment Permit

• IUP needs revision when
• IUP conditions not strong enough to protect WWTP
  including collection system and sludge, as well
  as the environment and public health
• IUP conditions difficult to enforce
• IUP conditions too stringent and could be relaxed
  and still protect POTW

26
IUP Industrial User Pretreatment Permit

• Find your IUPs
• Understand and follow them!
• Comprehensive Guide, Chapter 6 - IUPs
• Coming soon - One-day workshop on IUPs
• If IUP doesnt do what you need it to do, change
  it!
• Too harsh, too weak, interferes with what you
  need to do to protect your POTW