Introduction to Industrial User Permitting

Transcription

1 OBG PRESENTS: Introduction to Industrial User Permitting NCMA EEHS School, Raleigh, NC August 8, 2017

2 Introducing Deborah Gore PERCS Unit Supervisor, NCDEQ DWR Rachel Burris, PE Engineer 3, OBG 2

3 AGENDA Pretreatment Program Overview Industry Permit Application Process Developing Permit Limits Modifying Permit Noncompliance and Enforcement 3

4 Pretreatment Program Overview 4

5 Framework for publicly owned treatment works (POTWs) to regulate the discharges they receive from industries What is a Pretreatment Program? Protects POTW employee health and safety, collection system, WWTP, waste sludge quality, and receiving stream NCDEQ delegates approved municipalities to implement program 113 active pretreatment programs 626 active significant industrial users (SIUs) Elements Industrial user permits (IUPs) Enforcement response plan Headworks analysis Sewer use ordinance Industrial waste survey Long/short-term monitoring plan 5

6 Industrial Users Dischargers to POTW Residential Industrial Commercial Industrial User Significant Industrial User Non-Categorical Categorical 6

7 Significant Industrial User Significant Industrial User (SIU) Non-Categorical Categorical > 25,000 gpd process wastewater > 5% MAHL for BOD, TSS, NH 3 Potential for adverse impact to POTW Facility s industrial activity is regulated by one of the categories identified in 40 CFR Any volume of process wastewater (unless non-significant CIU exception) 15A NCAC 2H.0903(b)(33) 7

8 IUP Applicability My company just acquired this facility and we don t have an IUP. An employee said that 5 years ago the City said we didn t need an IUP. Do we need one now? My company is starting manufacturing operations and will not be a SIU at start-up, but may be in 5 years. Do we need to talk to POTW now? My facility is a categorical user. Does that mean the IUP will have categorical limits? 8

9 IUP Application Process 9

10 Industrial User Wastewater Survey & Permit Application 10

11 POTW uses the form to collect industrial user information Industrial User Wastewater Survey & Permit Application Information used to determine whether an IUP is required Provides wastewater characteristics to aid POTW in defining flow/load limits Form serves as a survey form, once per 5 years, for all industrial users (per regulations) and as a permit application form for SIUs Key numerical information is water balance and analytical data 11

12 Water Balance Flow: measure or estimate? Purchased water that does not discharge to POTW Evaporative loss, irrigation, ingredient water, hauled waste Quantifies the process wastewater flow to the POTW 12

13 Data, Data, and More Data 2-Chlorophenol 2,4-Dichlorophenol 2,4-Dimethylphenol 2,4-Dinitrophenol 2-Methyl-4,6-dinitrophenol 4-Chloro-3-methylphenol 2-Nitrophenol 4-Nitrophenol Pentachlorophenol Phenol 2,4,6-Trichlorophenol 1,2,4-Trichlorobenzene 1,2-Dichlorobenzene 1,2-Diphenylhydrazine 1,3-Dichlorobenzene 1,4-Dichlorobenzene 2,4-Dinitrotoluene 2,6-Dinitrotoluene 2-Chloronaphthalene 3,3-Dichlorobenzidine 4-Bromophenyl phenyl ether 4-Chlorophenyl phenyl ether Acenaphthene Acenaphthylene Anthracene Benzidine Benzo (a) anthracene Benzo (a)pyrene Benzo(b)fluoranthene Benzo(ghi)perylene Benzo (k) fluoranthene Bis(2-chloroethoxy) methane Bis(2-chloroethyl) ether Bis(2-chloroisopropyl) ether Bis(2-ethylhexyl) phthalate Butyl benzyl phthalate Chrysene Di-n-octyl phthalate Dibenzo (a,h) anthracene Diethyl phthalate Dimethylphthalate Fluoranthene Fluorene Hexachlorobenzene Hexachlorobutadiene Hexachlorocyclopentadiene Hexachloroethane Indeno(1,2,3-cd) pyrene Isophorone Representative Method and Sample Sample N-nitroso-di-n-propylamine N-nitrosodimethylamine N-nitrosodiphenylamine Naphthalene Nitrobenzene Phenanthrene Laboratory Pyrene Di-n-butylphthalate sample(s) Aluminum detection Antimony limitarsenic Beryllium locationcadmium Chromium type Copper Lead Mercury Molybdenum Nickel Selenium Silver Thalium Zinc Barium Chloride Cyanide Fluoride1,1,1-Trichloroethane 1,1,2,2-Tetrachloroethane 1,1,2-Trichloroethane 1,1-Dichloroethane 1,1-Dichloroethylene 1,2-Dichloroethane 1,2-Dichloropropane 2-Chloroethyl vinyl ether Acrolein Acrylonitrile Benzene Bromodichloromethane Bromoform Bromomethane Carbon tetrachloride Chlorobenzene Chloroethane Chloroform Chloromethane cis 1,3-Dichloropropene Dibromochloromethane Ethylbenzene Methylene chloride Tetrachloroethylene Toluene trans 1,3-Dichloropropene trans-1,2-dichloroethylene Trichloroethylene Trichlorofluoromethane Vinyl chloride Biological oxygen demand Chemical oxygen demand Total suspended solids Ammonia Total phosphorus Nitrate Nitrite 13

14 IUP Application My facility is under construction and I don t have wastewater to sample. How do I complete the monitoring section? The only flow measurement at my facility is the potable water meter. How would I gather the data to complete the water balance section? It is time to submit an IUP renewal application and my facility is currently operating at a lower production rate than normal. Samples collected this month won t reflect the typical total load. How do I gather representative sampling data for the application? 14

15 Developing IUP Limits 15

16 POTW conducts a headworks analysis Limit Development Most limiting influent load the POTW can receive based on either: Inhibition of biological treatment NPDES limits/water quality standards Design load of the POTW Sludge disposal requirements flow/load limits Allowable industrial load is the difference between maximum influent load and the domestic load Example permit 16

17 IUP Limits Is the POTW allowed to impose a limit that is less than a typical domestic wastewater concentration? I am new to the facility. How do I determine the basis for the existing IUP limits? My facility s IUP includes both concentration and mass limits for the same parameters. Why? What is NCDEQ s role in issuing IUPs? 17

18 Modifying Permit 18

19 IUP Modification My facility is adding a new product and needs to request a change in IUP limits. How do I make that request? How long does it take from the time of the request to the effective date of a permit modification? 19

20 Noncompliance and Enforcement 20

21 Noncompliance and Enforcement My facility received a fine that was larger than expected. Can the POTW impose such a high fine? The sample the facility collected was in compliance. The sample the POTW collected on the same day exceeded the limit. Which results are used to judge compliance? Can a fine for monthly average flow violation be assessed for each calendar day in the month if the facility only discharges on weekdays? What is the difference between a Notice of Noncompliance, Notice of Violation, and Significant Noncompliance? 21

22 OBG PRESENTS: THERE S A WAY Questions? Deborah.Gore@ncdenr.gov Rachel.Burris@obg.com