Transcript Industrial Wastewater Permits

INDUSTRIAL WASTEWATER PERMITS
2016 ENVIRONMENTAL TRADE FAIR
SHANNON GIBSON
ENVIRONMENTAL PERMIT SPECIALIST
(512) 239-4284
OVERVIEW
• WHO NEEDS A PERMIT
• PROCESSING
• TIPS FOR COMPLETING THE APPLICATION
WHO NEEDS A PERMIT
• PURSUANT TO THE TEXAS WATER CODE §26.121:
FACILITIES (MOBILE OR STATIONARY) CANNOT DISCHARGE WASTEWATER INTO OR ADJACENT TO
ANY WATER IN THE STATE WITHOUT APPROPRIATE AUTHORIZATION.
• TYPES OF PERMITS
• INDIVIDUAL AUTHORIZATIONS FOR DIRECT DISCHARGES AND LAND APPLICATION
• GENERAL PERMITS
• PERMITS BY RULE
WHO NEEDS A PERMIT
• QUESTIONS? NEED HELP?
• CALL THE TCEQ AT (512) 239-4671 AND SPEAK WITH AN INDUSTRIAL PERMIT WRITER
• CALL THE SMALL BUSINESS AND LOCAL GOVERNMENT ASSISTANCE HOTLINE AT
(800) 477-2827
PROCESSING THE APPLICATION
• APPLICATION PROCESSING TIMEFRAMES
• THE PERMITTING PROCESS
APPLICATION PROCESSING TIMEFRAMES
• NEW APPLICATION – 330 DAYS
• MAJOR AMENDMENT
• MAJOR FACILITIES – 330 DAYS
• MINOR FACILITIES – 300 DAYS
• RENEWAL
• MAJOR FACILITIES – 330 DAYS
• MINOR FACILITIES – 300 DAYS
APPLICATION PROCESSING TIMEFRAMES
• TIMEFRAMES MAY BE EXTENDED IF:
• EPA ISSUES OBJECTIONS TO THE DRAFT PERMIT
• TCEQ RECEIVES REQUEST(S) FOR A PUBLIC MEETING OR CONTESTED CASE
HEARING
THE PERMITTING PROCESS
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ADMINISTRATIVE REVIEW
1ST PUBLIC NOTICE – NORI (PUBLIC COMMENTS)
TECHNICAL REVIEW
PERMIT DEVELOPMENT
2ND PUBLIC NOTICE - NAPD (PUBLIC COMMENTS)
(EPA REVIEW / OBJECTIONS)
(PUBLIC MEETING / CONTESTED CASE HEARING)
AGENCY DECISION – ISSUANCE OR DENIAL OF PERMIT
ADMINISTRATIVE REVIEW
• ADMINISTRATIVE REPORT
• APPLICATION CONTACT AND SITE INFORMATION
• NOTICE INFORMATION
• LANDOWNER INFORMATION
• RESPOND PROMPTLY TO REQUESTS FOR ADDITIONAL INFORMATION.
DELAYING YOUR RESPONSE DELAYS YOUR PERMIT.
ST
1
PUBLIC NOTICE - NORI
• NORI – NOTICE OF RECEIPT OF APPLICATION AND INTENT TO OBTAIN A WATER
QUALITY PERMIT
• MAILED TO APPLICANT FOR PUBLICATION AFTER THE APPLICATION IS DEEMED
‘ADMINISTRATIVELY COMPLETE’
• PUBLISH PROMPTLY AND RETURN DOCUMENTATION TO THE CHIEF CLERK’S OFFICE (CCO)
• A DRAFT PERMIT CANNOT BE FILED WITH THE CCO IF THE NORI PROCESS IS INCOMPLETE
DELAYS IN PUBLICATION OR DOCUMENT SUBMITTAL DELAYS YOUR PERMIT
TECHNICAL REVIEW
• WATER QUALITY STANDARDS
• USES AND CRITERIA
• ANTI-DEGRADATION
• ENDANGERED SPECIES
• CRITICAL CONDITIONS
• CRITICAL FLOWS OR MIXING CONDITIONS
• MIXING ZONE DEFINITION
TECHNICAL REVIEW
• DISSOLVED OXYGEN (DO) MODELING
• IMPACT OF DISCHARGE(S) ON DO OF RECEIVING WATER(S)
• WATER BODY IMPAIRMENTS
• COMPLETED TOTAL MAXIMUM DAILY LOADS (TMDLS)
• BIOMONITORING
• WHOLE EFFLUENT TOXICITY (WET) TESTING OR LIMITS
• SPECIES, FREQUENCY, DILUTIONS
TECHNICAL REVIEW
• AGRONOMY
• CROPS
• SOIL TESTING
• HYDROGEOLOGY
• POND LINER REQUIREMENTS
• BUFFER ZONES
• GROUNDWATER MONITORING
PERMIT DEVELOPMENT
• DATA COMPLETENESS REVIEW
• COMPLIANCE HISTORY
• SELF-REPORTED EFFLUENT DATA (DMRS)
• TECHNOLOGY-BASED EFFLUENT LIMITATIONS
• WATER QUALITY-BASED EFFLUENT LIMITATIONS
• FINAL EFFLUENT LIMITATIONS
• MOST STRINGENT OF TECH-BASED, WATER QUALITY-BASED, AND EXISTING PERMIT LIMITATIONS
PERMIT DEVELOPMENT - REVIEWS
• TEAM LEADER
• APPLICANT
• (LEGAL)
• (OTHER TECHNICAL STAFF)
ND
2
PUBLIC NOTICE - NAPD
• NAPD– NOTICE OF APPLICATION AND PRELIMINARY DECISION
• MAILED TO APPLICANT FOR PUBLICATION AFTER THE DRAFT PERMIT IS ACCEPTED BY THE
APPLICANT
• PUBLISH PROMPTLY AND RETURN DOCUMENTATION TO THE CCO
DELAYS IN PUBLICATION OR DOCUMENT SUBMITTAL DELAYS YOUR PERMIT
• IF PUBLIC COMMENTS ARE RECEIVED, THE PERMIT WRITER AND LEGAL PREPARE A RESPONSE
TO COMMENTS DOCUMENT
EPA REVIEW
• EPA REVIEWS THE DRAFT PERMIT
• APPROVAL
• OBJECTION ISSUED
• THE PERMIT WRITER RESPONDS TO ANY OBJECTIONS RECEIVED FROM EPA
• CLARIFICATION
• PERMIT REVISION
PUBLIC MEETING REQUESTS
AND CONTESTED CASE HEARINGS
• IF A PUBLIC MEETING IS HELD, THE COMMENT PERIOD IS TYPICALLY EXTENDED TO THE END
OF THE MEETING
• REQUEST(S) FOR CONTESTED CASE HEARINGS – GRANTED OR DENIED
AGENCY DECISION
• ISSUANCE
• DENIAL
FORMS AND INSTRUCTIONS
• APPLICATION FORMS AND INSTRUCTIONS, PLUS ADDITIONAL INFORMATION SUCH AS THE
SPANISH LANGUAGE NOTICE TEMPLATES, ARE AVAILABLE AT THE FOLLOWING TCEQ
WEBSITE:
https://www.tceq.texas.gov/permitting/wastewater/industrial/TPDES_industrial
_wastewater_steps.html
NOTE: UPDATED FORMS WERE PUBLISHED TO THE TCEQ WEBSITE MARCH 2016.
COMPLETING THE APPLICATION FOR A PERMIT
• READ THE INSTRUCTIONS (!)
• STILL NOT SURE HOW TO FILL OUT A PART OF THE APPLICATION?
• CALL THE WATER QUALITY DIVISION AT (512) 239-4671
AND ASK TO SPEAK WITH AN INDUSTRIAL PERMIT WRITER
• DO NOT LEAVE ANY ITEMS OR QUESTIONS BLANK
• ENTER “N/A” IF NOT APPLICABLE
• PROVIDE COMPLETE INFORMATION EACH TIME YOU SUBMIT AN INDUSTRIAL WASTEWATER
PERMIT APPLICATION
• YES, EVEN FOR RENEWALS.
TIPS FOR COMPLETING THE TECHNICAL REPORT
• ITEM 1 – WASTEWATER GENERATION
• DESCRIBE ALL PROCESSES THAT GENERATE WASTEWATER
• INCLUDE LEGIBLE FACILITY MAPS AND DIAGRAMS
• ITEM 2 - TREATMENT
• DESCRIBE TREATMENT SYSTEMS, IF ANY. ERR ON THE SIDE OF TOO MUCH DETAIL
• INCLUDE THE FLOW SCHEMATIC WITH A WATER BALANCE
TIPS FOR COMPLETING THE TECHNICAL REPORT
• ITEM 3 - IMPOUNDMENTS
• LINER TYPE
• STORAGE VOLUME
• SURFACE AREA
• COMPLIANCE WITH 40 CFR PART 257, SUBPART D?
TIPS FOR COMPLETING THE TECHNICAL REPORT
• ITEM 4 – OUTFALLS
• 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
• SUM OF PERCENTAGES MUST EQUAL 100%
• MAKE SURE THE INFORMATION IN THE TABLE IS CONSISTENT WITH THE FLOW
SCHEMATIC/WATER BALANCE
TIPS FOR COMPLETING THE TECHNICAL REPORT
• ITEM 4 CONT. - OUTFALLS
NOTE: LOW-VOLUME WASTE SOURCES MAY NOT INCLUDE WASTESTREAMS FROM THE
FOLLOWING PROCESSES:
• COMBUSTION RESIDUAL LEACHATE
• FLUE GAS DESULFURIZATION
• FLUE GAS MERCURY CONTROL, OR
• GASIFICATION.
TIPS FOR COMPLETING THE TECHNICAL REPORT
• ITEMS 12 THRU 14 – AMENDMENT AND MODIFICATION REQUESTS
• TRY TO INCLUDE ALL AMENDMENT OR MODIFICATION REQUESTS UPFRONT
** NOT INCLUDING ALL REQUESTS UPFRONT CAN DELAY PROCESSING **
• CLEARLY EXPLAIN ALL AMENDMENT OR MODIFICATION REQUESTS
• QUESTIONS ABOUT AN AMENDMENT OR MODIFICATION?
• CALL AN INDUSTRIAL PERMIT WRITER AT (512) 239-4671
• REQUEST A PRE-APPLICATION MEETING
TIPS FOR COMPLETING THE TECHNICAL REPORT
• WORKSHEET 2.0 – POLLUTANT ANALYSIS
• PLAN AHEAD!
• BEGIN SAMPLING AND ANALYZING EFFLUENT SO THAT ALL REQUIRED DATA CAN BE SUBMITTED
WITH THE APPLICATION.
• APPLICATIONS ARE NO LONGER PROCESSED WITHOUT ANALYTICAL DATA. EXCEPTIONS:
• NEW FACILITIES
• FACILITIES WITH NO DISCHARGES DUE TO DROUGHT OR OTHER CIRCUMSTANCES
TIPS FOR COMPLETING THE TECHNICAL REPORT
• WORKSHEET 2.0 CONT.
• ANALYTICAL LABS MUST BE NELAC-CERTIFIED
• ENSURE THE SIGNED CERTIFICATION STATEMENT IS SUBMITTED WITH THE APPLICATION
• MINIMUM ANALYTICAL LEVELS (MALS) IN THE JUNE 2010 IMPLEMENTATION PROCEDURES
WERE APPROVED BY THE 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
TIPS FOR COMPLETING THE TECHNICAL REPORT
• WORKSHEETS 3.0 THRU 3.3 – TEXAS LAND APPLICATION PERMITS (TLAPS)
• WATER BALANCE
• NEEDED TO CALCULATE ALLOWABLE LAND APPLICATION RATES AND STORAGE VOLUMES (WHEN
STORAGE IS REQUIRED)
• INFORMATION NEEDED FOR LAND APP:
• CURVE NUMBER (CN)
• EFFLUENT CONDUCTIVITY (CE)
• MAXIMUM ALLOWABLE CONDUCTIVITY
OF SOIL SOLUTION
(CL)
• IRRIGATION EFFICIENCY (K)
TIPS FOR COMPLETING THE TECHNICAL REPORT
• WORKSHEET 11.0 – COOLING WATER INTAKE STRUCTURES
• COMPLETE THIS WORKSHEET IF THE FACILITY USES WATER FOR COOLING PURPOSES.
• THIS INCLUDES ALL FACILITIES REGARDLESS OF:
•
THE COOLING SYSTEM TYPE
•
METHODS USED TO OBTAIN COOLING WATER
• SOURCE WATER
MORE INFORMATION NEEDED?
• TCEQ INDUSTRIAL PERMITS TEAM: (512) 239-4671
• TCEQ WEBSITE: https://www.tceq.texas.gov/
QUESTIONS?
SHANNON GIBSON
ENVIRONMENTAL PERMIT SPECIALIST
(512) 239-4284