A Class I Permit is issued to any user who meets any one of the following conditions:

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1 chapter 3 PERMITS 3.1 INTRODUCTION The Orange County Sanitation District s (District) Industrial Wastewater Discharge Permit System was implemented to establish control mechanisms which contain effluent limits for all standards; statements of duration and non-transferability; self-monitoring, sampling, reporting, record keeping and notification requirements; and statements of applicable civil and criminal penalties for discharge violations. The following sections describe the different classifications of permits, how new permittees are identified, and how discharge limits are established. 3.2 PERMIT CLASSIFICATIONS There are five permit classifications for users that discharge waste to the District s sewerage system: Class I, Class II, Wastehaulers, Special Purpose, and FOG (Fats, Oils, and Grease),. Class I Permits Class I dischargers are defined as Significant Industrial Users (SIUs) in accordance with Federal regulations. These users include plating shops, printed circuit board shops, large food processors and textile companies with high-volume flows, and industries capable of discharging non-compatible pollutants. A listing of the Class I permittees is given in Appendix A. A Class I Permit is issued to any user who meets any one of the following conditions: 1. Is subject to federal Categorical Pretreatment Standards; or 2. Averages 25,000 gallons per day or more of regulated process wastewater; or 3. Is determined by the General Manager to have a reasonable potential for adversely affecting the District s operation or for violating any pretreatment standard, local limit, or discharge requirement; or 4. May cause, as determined by the General Manager, pass through or interference with the District s sewerage facilities. Class II Permits Class II permittees include commercial enterprises such as restaurants, supermarkets, and coin-operated laundries. A Class II Permit is issued to any user who meets all of the following conditions: 1. Has a charge for use greater than the ad valorem tax basic levy allocated to the District; and 2. Discharges waste other than sanitary; and 3. Is not otherwise required to obtain a Class I permit. 3.1

2 Wastehauler Permits Wastehauler permits are issued to those users who are engaged in vehicular transport and subsequent disposal of biodegradable waste into the District's system. Wastehauler permittees dispose of septic tank/cesspool, restaurant grease trap and portable toilet wastes at the District s dedicated disposal facility located at Reclamation Plant No. 1 in Fountain Valley. The discharge of industrial wastewater by any wastehauler is prohibited unless written permission of the District s General Manager has been obtained. Special Purpose Permits Special Purpose permits are issued to dischargers for the purpose of discharging groundwater, surface run-off, subsurface drainage, or unpolluted water directly or indirectly to the District s facilities, on a temporary basis, when no alternative method of disposal is reasonably available, or to mitigate an environmental risk or health hazard. This presently includes groundwater remediation projects. FOG (Fats, Oil, and Grease) Permits OCSD is administering the local FOG Program for Food Service Establishments (FSEs) that discharge to sewer lines in the City of Tustin area which are maintained by OCSD. Ordinance OCSD-25 provides for establishment of the FOG program and enforcement of program requirements by OCSD s FOG Program Manager and General Manager. The goal of the program is to eliminate Sewer Service Overflows (SSOs) which emanate from FSEs. Additional information can be found in Chapter PERMIT ISSUANCE At the end of FY 2004/05, the District administered 725 active permits as summarized in Table 3.1. TABLE 3.1 Number of Permits Administered for Fiscal Years Orange County Sanitation District Fiscal Year Class I* Class II Wastehauler Special Purpose FOG Total 2000/ / / / / This level of permit activity represents a 24% increase compared to the total number of active permits in the previous fiscal year. The was due to the FOG permits which had not been issued prior to this fiscal year. Of the 385 Class I permittees, 249 were subject to Federal Categorical Pretreatment Standards. The following sections describe the District s permitting process and how discharge limits are established. 3.2

3 3.3.1 Identification of New Permittees Each year, the District has access to various listings for companies that may be subject to Federal Categorical Standards or local limits. Wastewater permits are issued to those firms as required. Listings used for identification of new permittees include: Telephone books Business licenses Standard Industrial Classification Code listings Newspaper advertisements Industry, trade or association magazines Review of the County of Orange Health Care Agency, Hazardous Waste Division list of hazardous waste generators These sources are used primarily to identify new Class I users. Identification of new Class II users may be done by a computerized or manual search of water purveyor records or local cities' business licenses. Some City building departments also contact the District s Source Control Division when they become aware a new industry has located in their city. 3.4 DISCHARGE LIMITS Industrial In 1976, the District established discharge limits for specific pollutants. These limits became increasingly restrictive over a three-phased implementation period designed to give industry adequate time to comply with the more stringent standards. All of the limiting values were adopted by the District s Boards of Directors in 1976 and were published in the District s Regulations for Use of District Sewerage Facilities (Discharge Ordinance). New concentration limits were adopted in the revised Discharge Ordinance, which became effective July 1, On September 8, 1989, the Boards of Directors adopted a new ordinance entitled Wastewater Discharge Regulations (WDR Ordinance) which contained essentially the same concentration limits as the previous Discharge Ordinance. Revisions consisted of creating a specific limit of 0.1 milligram per liter (mg/l) for PCB, and a limit of 0.1 mg/l for pesticides, and creating specific limits for wastehaulers. It also included specific discharge limits for biochemical oxygen demand (BOD). The daily maximum BOD limit is 15,000 pounds per day (lb/day) and the 30-day average BOD limit is 10,000 lb/day. These limits were established to prevent pass-through and interference. The 1989 WDR Ordinance was subsequently revised in February 1992 and July 1998, but with no change to the local discharge limits (see Table 3.2). Since the implementation of the Federal Categorical Standards in April 1984, the District applies either the Federal Categorical Standards or the District s local discharge limits, whichever are the more stringent Wastehaulers After evaluating reference materials from the EPA and laboratory results from wastehauler samples taken by the District, pollutant limits were established for wastehaulers discharging domestic waste that approximate the maximum expected heavy metal concentrations from domestic wastes found in septic tank/cesspool wastes. These limits are shown in Table

4 TABLE 3.2 District s Discharge Limits in Milligrams Per Liter (mg/l) Orange County Sanitation District Limit (mg/l) Limit (mg/l) Arsenic 2.00 Cyanide (Total) 5.00 Cadmium 1.00 Cyanide (Amenable) 1.00 Chromium (Total) 2.00 Polychlorinated Biphenyls 0.01 Copper 3.00 Pesticides 0.01 Lead 2.00 Total Toxic Organics 0.58 Mercury 0.03 Sulfide (Total) 5.00 Nickel Sulfide (Dissolved) 0.50 Silver 5.00 Oil and Grease of Mineral Zinc or Petroleum Origin Limits for Wastehaulers Discharging Domestic Waste Limit (mg/l) Cadmium 1.0 Chromium Copper Lead Nickel Zinc ESTABLISHING MASS EMISSION RATES (MER) The District uses a dual approach to regulating wastewater constituents. In order to encourage water conservation, waste minimization, and recycling; to limit the total pounds of pollutants that enter the treatment facilities; and to deter achieving compliance through dilution; permits are issued with both concentration-based limits and mass emission limits. For concentration limits, the District applies either the Federal Categorical Standards or the District s local discharge limits (shown in Table 2.2), whichever are the more stringent. Allowable mass emission rates are calculated using the applicable concentration limits in combination with an industry's three-year average wastewater flow (or base flow rate). The base flow rate is determined at the time a permit is initially issued or reissued. The volume of wastewater used in establishing a permittee's limits is based on water meter information or additional substantiating reports submitted to the District. All new companies locating within the District s service area are issued mass emission rates (MERs), usually calculated on an estimated daily city water meter use until a sufficient water usage/discharge data base can be established. This process typically takes about one year. Unless additional water losses can be substantiated, 95% of the influent city water meter reading is considered to be discharged to the sewer. The remaining 5% is a standard allowance for losses in process, evaporation, and landscaping. An allowance for domestic waste is computed based on a daily usage rate of 25 gallons per employee per 8-hour shift. If there is documentation showing other 3.4

5 water losses, such as product water loss or boiler loss, that are greater than the standard 5% deduction, then adjustments can be made to accommodate these losses. If water conservation beyond normal industrial practice takes place, the permitted flow may be adjusted to account for water conservation and/or water recycling. The user's annual average industrial wastewater discharge, calculated as described above, is divided by the number of days worked per year to yield the net discharge in gallons per day. Also, because the limit in lbs/day provides a pollutant "ceiling", the user is prevented from introducing large quantities of water in an attempt to dilute concentrations to meet categorical requirements. If an industrial discharger wishes to increase production by expanding capacity or by increasing the number of hours worked, pretreatment capabilities must be increased to meet the future requirements to ensure long-term compliance with the applicable limits. If a permittee exceeds the MER or concentration discharge limits, the violation is subject to a noncompliance sampling fee as specified in the Ordinance Establishing Source Control Fees, Administrative Fees, Non-Compliance Sampling Fees, and Miscellaneous Charges, and may be subject to administrative penalties as provided in the WDR Ordinance. 3.5